The regulatory requirement to develop an upgraded safety basis for a DOE nuclear facility was realized in January 2001 by issuance of a revision to Title 10 of the Code of Federal Regulations Section 830 (10 CFR 830).1 Subpart B of 10 CFR 830, "Safety Basis Requirements," requires acontractor responsible for a DOE Hazard Category 1, 2, or 3 nuclear facility to either submit by April 9, 2001 the existing safety basis which already meets the requirements of Subpart B, or to submit by April 10, 2003 an upgraded facility safety basis that meets the revised requirements.110 CFR 830 identifies Nuclear Regulatory Commission (NRC) Regulatory Guide 1.70, "Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants"2 as a safe harbor methodology for preparation of a DOE reactor documented safety analysis (DSA). The regulation also allows for use of a graded approach. This report presents the methodology thatwas developed for preparing the reactor accident analysis portion of the Advanced Test Reactor Critical Facility (ATRC) upgraded DSA. The methodology was approved by DOE for developing the ATRC safety basis as an appropriate application of a graded approach to the requirements of 10 CFR 830.