My first thought was 8, so I'll take the under. Although a few of the 8 will no doubt be back breaking, soul crushers.
If the defense was capable of consistently getting a turnover a game, I'd take the over in a heartbeat.
I'm gonna take the over and predict 10. Seems to me they are on pace for 130+ penalties. They already have 31 penalties in 4 games. NOT the sign of a well coached team., thought I would add that too.