Thank you all for your input. As the regulator I have had concerns about using inside wiremen for medium voltage work and have shut them down for the last 2 years until they could show me the following:
1. Medium voltage Procedures
2. Medium voltage training program
3. Necessary tools & PPE
They came back and said they are ready to show me their program, training, PPE, and tools but when I looked at what they had, I found that they were not using grounding clusters because they said that 10 CFR 1910.269(n) did not require it if it was “impractical”. I still have them shut down and have been trying to show them that it is practical if they make minor modifications to the elbows during the next site shutdown. Installing ground clusters can be the difference between life and death and should not be eliminated because they are “impractical”. Our local utility linemen have been very helpful and knowledgeable in helping me present a practical solution. I was just using this form to see if there were other ideas out there.