Digital I&C replacement, cybersecurity qualification and equivalency testing against analogue baselines

    Commissioning software for nuclear I&C upgrades where a digital replacement for an analogue safety system has to prove functional equivalence, not just that the new screen looks right.

    Replacing analogue reactor protection and engineered safety features actuation systems with digital platforms is one of the highest-scrutiny modification classes in nuclear commissioning, requiring functional equivalence testing against the original analogue response, cybersecurity qualification and independent verification that common-cause failure has been adequately addressed. Deskely holds the original analogue baseline, the digital platform's qualification record and the site acceptance test in one register, so equivalence is demonstrated with evidence rather than asserted.

    Assets
    RPS/ESFAS cabinets, digital modules, cabling
    Test
    Functional equivalence, cybersecurity, response time
    Basis
    Original analogue setpoints and response times
    Gate
    Safety system operational readiness
    REACTOR PROTECTION SYSTEM — DIGITAL UPGRADEI&C EQUIVALENCE RECORD SET · REV BANALOGUE RPS CABINET (BASELINE)DIGITAL RPS PLATFORMRPS-CAB-01Cybersecurity review pendingTAG REGISTERRPS-CH-BReactor protection channe…Records signedESFAS-DIV2ESFAS actuation, division…In testCYBER-SEG-04Network segmentation, saf…PreservationSP-RPS-B-04Original setpoint, channe…Punch open4 divisionsunder one system hierarchy

    The problem

    A digital upgrade has to match an analogue system it never operated alongside, and 'it passed the factory test' is not the same as 'it matches the licensing basis'.

    Reactor protection and engineered safety features actuation system upgrades replace analogue relay logic with digital platforms carrying different failure modes, different response time characteristics and new cybersecurity attack surfaces that the original analogue design never had to consider.

    When the original analogue setpoints and response times exist only in decades-old test records and the new digital platform's qualification testing happens in a completely separate vendor system, proving functional equivalence becomes a manual reconciliation exercise every time a reviewer asks a question.

    Deskely holds the original analogue baseline and the new digital platform's qualification and site acceptance records against the same system tag, so functional equivalence is a documented comparison rather than an assertion in a modification package summary.

    DIGITAL REPLACEMENT, NO EQUIVALENCY PROOFAnalogue reactor protection → digital I&CA digital replacement must prove equivalence, not just "does the same job"EQUIVALENCY TEST MATRIX — RPS CHANNEL AResponse time vs analogue baselineFailure mode and effects analysisCybersecurity qualification, isolation boundaryCommon cause failure diversity reviewREGULATOR REVIEW"Same as before, but digital" is not an evidence package2equivalency items open on channel A4RPS channels needing the same proofDeskely tracks equivalency evidence per channel, not a blanket "upgrade complete" milestone.

    Setting up the register

    Analogue baselines and digital replacement records are tagged assets structured for a direct equivalence comparison.

    Original analogue setpoint calculations, response time test records and the safety analysis basis they support are parsed into the register against the system being replaced, establishing the exact baseline the digital replacement has to match or improve on.

    The digital platform's factory qualification testing, including environmental qualification and electromagnetic compatibility testing, is registered against the same system tag, so a reviewer sees the vendor's qualification basis next to the plant-specific baseline it is being applied to.

    Cybersecurity requirements — network segmentation, access control, configuration management of firmware and application software — are tracked as their own record set, distinct from functional testing, because a digital I&C modification is reviewed against both functional and cybersecurity criteria independently.

    1 · SOURCE DOCUMENTSOriginal analogue setpoi…1990s baselineDigital platform qualifi…4 divisionsCybersecurity requiremen…1 assessmentCommon-cause failure ana…1 reportPARSE + MATCHtag · description · drawing ref2 · ONE TAG REGISTERRPS-CH-BReactor protection channe…RPSESFAS-DIV2ESFAS actuation, division…ESFASCYBER-SEG-04Network segmentation, saf…CYBERSP-RPS-B-04Original setpoint, channe…BASELINETWO DOCUMENTS DISAGREEOriginal analogue…Reactor protection channel BDigital platform …Abbreviated descriptionEngineer picks the sourcedecision loggedWeeks of transcription become a draft an engineer reviews.

    Execution

    Functional equivalence and cybersecurity verification are proven signal by signal before the digital system replaces its analogue predecessor.

    Functional equivalence testing exercises each protection channel against the original analogue setpoints and response time requirements, with pass/fail evaluated directly against the historical baseline rather than a fresh interpretation of the safety analysis.

    Cybersecurity verification confirms network segmentation, access controls and configuration management controls are in place and tested, captured as its own gate independent of functional testing, because a functionally correct system that fails cybersecurity review cannot proceed to service.

    Common-cause failure analysis findings and any diversity and defence-in-depth requirements are tracked against the specific channel or division they apply to, so the modification package's independent review has direct access to the test evidence supporting each claim.

    EQUIVALENCY TEST → CUTOVER LADDERRPS channel A, digital replacementEquivalency test matrix completeSigned — response time, FMEACybersecurity qualificationSigned — isolation boundary provenCommon cause failure diversity reviewIn progress — independent reviewerParallel run against analogue baselineAwaiting diversity review sign-offCutover to digital channelGated on parallel run evidence2of 5 gates cleared on channel A4RPS channels queued behind this oneCutover only happens once equivalence is proven, channel by channel.

    Safety system operational readiness

    The digital system enters service from a proven equivalence case, not a vendor's assurance that the new platform 'does the same thing, but digitally'.

    The safety system operational readiness review draws on the linked analogue baseline, digital qualification and site functional equivalence test records, giving the regulator a direct, evidenced comparison rather than a narrative equivalence argument.

    The updated configuration baseline reflects the new digital platform's setpoints, software version and cybersecurity configuration at the tag level, so future surveillance testing and any subsequent modification start from an accurate current-state record.

    Every equivalence test, cybersecurity verification and independent review carries a name, role and timestamp, which is the traceability a digital I&C modification's licensing review and cybersecurity assessment are both built to test.

    AUDIT QUERYRPS-CH-BReactor protection channel B, equivalence disputedComplete evidence chain for RPS-CH-BBL-CHBOriginal analogue setpointLicensing archive15 JanFE-CHBFunctional equivalence testI&C engineer20 FebCYB-CHBCybersecurity verificationCybersecurity leadpendingCERTIFICATESR-CHBChannel B operational readinesspendingIndependent reviewerPrerequisites demonstratedOperational readiness is blocked until cybersecurity verification for channel B is signed.

    Hold points on a modification that never touches concrete or piping

    A digital I&C modification still needs hold points and licence condition compliance evidence, even though the entire scope can be executed by a handful of engineers with laptops.

    The absence of physical construction on an I&C upgrade tempts a modification team into treating it as a software project with lighter QA than a mechanical scope, but a reactor protection or ESFAS replacement carries exactly the same licence condition compliance obligations as a physical system replacement, including hold points where the licensee or the regulator must witness a specific test before work proceeds to the next stage.

    A factory acceptance test hold point on the digital platform, a site acceptance test hold point after installation and a pre-service functional test hold point before the system is declared operational each need independent witness and sign-off, and skipping the distinction between them because 'it's just software' is precisely the kind of shortcut an independent nuclear assurance review is designed to catch.

    Deskely applies the same hold point, witness and disposition structure to an I&C modification's factory, site and pre-service test stages as it would to a mechanical system replacement, so the modification's licence condition compliance record looks like what the regulator expects to see, not like a vendor's internal software release notes.

    EQUIVALENCY DOSSIERRPS channel A, digital vs analogueEVIDENCE PACKAGEResponse time comparison, digital vs analogueFailure mode and effects analysisCybersecurity qualification fileDiversity and common cause failure reviewPARALLEL RUN LOGDigital channel runs alongside the retained analogue channelEvery discrepancy logged before the analogue channel is retired2 of 4evidence items signed on channel A4RPS channels needing the same dossierThe dossier proves equivalence channel by channel, not "digital is fine, generally."

    The equivalency evidence set

    Six record types prove a digital replacement performs at least as well as the analogue system it is retiring.

    An I&C upgrade replaces analogue equipment with digital systems that carry their own qualification, cybersecurity and failure-mode questions the original analogue design never had to answer. These records are what safety system operational readiness for the upgraded system is judged against.

    RECORDS PRODUCED6 typesEquivalency test recordExecuted before the digital system is…Cybersecurity qualification recordCompleted during platform qualification,…Software configuration baseline…Established at installation, updated…Common cause failure analysis…Referenced during platform selection and…Hold point sign-off on a…Captured during installation and…Safety system operational…Issued before the upgraded system…DOSSIERIndexed persubsystem and tagExport readyEach record lands in the same structure, so the dossier assembles itself.

    Equivalency test record

    That a digital replacement system meets or exceeds the response time, accuracy and failure behaviour of the analogue system it replaces, function by function.

    Executed before the digital system is placed in service.

    Cybersecurity qualification record

    That a digital I&C platform has been assessed against the applicable cybersecurity requirements for a safety-related or safety-classified application before installation.

    Completed during platform qualification, before installation.

    Software configuration baseline record

    That the exact software version, configuration and application logic installed on a safety-related digital system matches the version verified and validated for that application.

    Established at installation, updated with any subsequent change.

    Common cause failure analysis reference record

    That the digital platform's diversity and defence-in-depth arrangements have been assessed against common cause failure concerns specific to digital I&C.

    Referenced during platform selection and design review, before installation.

    Hold point sign-off on a non-invasive modification

    That a modification touching only cabinets, cabling and logic — not concrete or piping — still passed every hold point its ITP requires.

    Captured during installation and functional test of the upgrade.

    Safety system operational readiness record

    That the upgraded safety-related function has been returned to service with its response verified end to end, from sensor input to actuated output.

    Issued before the upgraded system resumes protective duty.

    How it runs

    From analogue baseline recovery to safety system operational readiness.

    I&C upgrade programmes reward recovering the original analogue baseline before qualification testing begins, because equivalence cannot be demonstrated against a baseline nobody can locate.

    1. 01

      Recover the analogue baseline

      Original setpoints, response times and safety analysis basis parsed into the register against the system being replaced.

    2. 02

      Register digital qualification

      Vendor factory qualification and environmental testing tagged against the same system for direct comparison.

    3. 03

      Test equivalence and cybersecurity separately

      Functional equivalence and cybersecurity verification tracked as independent gates, each with its own evidence.

    4. 04

      Update the configuration baseline

      New setpoints, software version and cybersecurity configuration recorded at the tag level for future surveillance.

    FAQ

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