ISSUES REGARDING THE OZONE AIR-QUALITY STANDARD AND THE DESIGN VALUE

Two problems exist in the form and the compliance test of the present National Ambient Air Quality Standard (NAAQS) for ozone. One is the use of the number of exceedances in the form of the standard, which generates confusion and unnecessary complexity when the form is translated to the design value. The other is the requirement of a zero percent chance of violation in the compliance test, which makes the NAAQS considerably more stringent than generally assumed. There are also two sample-size problems in the estimation procedure for the design value. One is the upward creeping of the (n+1)th highest value in n years as n increases from one in the table look-up approach. The other is the infinite-sample-size assumption instead of the number of high-ozone season days per year for the daily maximum ozone concentrations in the distribution fitting approach. Both problems lead to an exaggeration of the design value. The above problems can be removed in a revised NAAQS by (1) using a statistic that is identical to the design value itself in the form of the standard, (2) defining the design value as an n-year mean of, say, the annual mth highest values rather than the xth highest value in n years, and (3) using a simple compliance test like the t test that compares the design value with the level of the standard, taking into account the year-to-year fluctuation of the annual mth highest values. When the design value of an area is close to the level of the standard, the test provides a natural ''too close to call'' interval, which adjusts itself with the fluctuation of the annual mth highest values, so that as the fluctuation increases, the ability to assign the compliance status of the area decreases. The inclusion of a ''too close to call'' interval or category in the standard is critical to reduce the tendency toward ozone attainment flip-flops in areas approaching attainment and to assure that the ozone NAAQS is not more or less stringent than it appears.