DOE is employing the principle of comparability with the NRC requirements to guide its safety program. Since the safety record of research reactors licensed by the NRC has been established and accepted, the comparison of DOE Orders applicable to DOE research reactors with the NRC regulations applicable to research reactors would identify strengths and weaknesses of the DOE Orders. The comparison was made in 14 general topics of safety which are labeled Areas of Safety Concerns. This paper focuses on the Area of accident analysis and safety review and presents recommendations in these areas. 12 refs.