No, I think that this rating just has an extremely high bar for what it considers failing. If I read this right you could fail by having 10 orange days over 3 years.

To support this they state,

For short-term particle pollution, fewer unhealthy air days are required for an F than for nonattainment under the PM2.5 standard. The 2006 24-hour PM2.5 standard is set to allow two percent of the days during the three years to exceed 35 µg/m3 (called a “98th percentile” form) before violating the standard. That would be roughly 21 unhealthy days in three years. The grading used in this report would allow only about one percent of the days to be over 35 µg/m3 (called a “99th percentile” form) of the PM2.5. The American Lung Association supports using the tighter limits in a 99th percentile form as a more appropriate standard that is intended to protect the public from short-term episodes or spikes in pollution.

So 21 orange days in 3 years represents 98th percentile and they are looking at 99th, so 10 days sounds about right.

I think 35 ug/m^3 is AQI 100…