How to draw, build and evidence the boundaries that keep BES Cyber Systems reachable only through controlled access points.
Segmentation is only as good as your inventory. Before drawing any boundary, list the BES Cyber Systems identified under CIP-002 and every device that talks to them — relays, RTUs and RTACs, HMIs, historians, engineering workstations, network gear.
For each one, record what it needs to talk to and why. That list of required flows becomes your rule base; anything not on it is denied.
A flat ESP still lets one compromised workstation reach every relay. Split it into zones by function — control, protection, engineering, historian/DMZ — and allow only the flows each zone needs.
Put anything that must reach the corporate network (historian replicas, patch staging, remote-access jump hosts) in a separate DMZ between the ESP and IT, never with a direct path through.
Auditors want to see that the design is real: current firewall configurations, the documented reasons for each rule, review records, and logs showing access through the EAPs. Collect them continuously rather than assembling screenshots before an audit.
General guidance, not legal or compliance advice. Your obligations depend on your registration and assets — confirm them with your compliance team and Regional Entity.