Making this work without a total rewire sounds like a tremendous headache and more importantly a can of worms. Probably end up losing money on this deal. I would most likely decline this job.
No contractor does this, since these projects don’t pay and aren’t worth it.
Since, housing-authority inspection corrections are required during occupancy, for me the nightmare is municipal inspectors failing these GFCI installs, with their departments ignoring 406.4(D)(2) code references. If any comment is made, it demands complete building rewire.
In my case, AHJ’s go on high alert with any owner-builder permit, synonymous with laborers doing it, since Supreme court precedent punishes AHJ’s that tolerate unskilled persons that do electrical,
Lowe v. Lowndes County Building Inspection Department, 760 So. 2d 711 (Miss. 2000).
There are no contractors that waist their time with 406.4(D)(2), and when attempted by a contractor’s side-worker employee, weekend warrior, or if DIY home owners try it themselves, there is no chance of passing inspection. In absence of any standard-operating proof of skills from the owner builder, and their laborers, AHJ’s are failing this regardless of installation perfection.
Even though I've kept busy with a fair T&M rate from these service calls, satisfying requirements for a letter ruling from State-wide insurance organizations may be the only AHJ that authorizes it.
Much less will State certified, licensed, or Master electrician's pass these inspections by using "GFCI Protected" stickers, unless each plug also has the "No Equipment Ground" sticker, affixed to each outlet, in compliance with 406.4(D)(2). This is 1 of many discrepancies IAEI educated inspectors are specifically trained to look for.
Further, a thorough inspection to 406.4(D)(2) is not likely to pass without proving exceptions to 250.114 are met in each case. If you can’t control the cheep appliances & their cords sets, which consumers buy, assuring compliance with 250.114 is not likely.
Where replacement code 406.4(D)(4) now demands AFCI protection I prefer breakers, especially for switched-lighting outlets, unless not available for old fuse boxes. Where replacement code demands GFCI protection, outlets are preferred, unless reset buttons would be buried behind furniture.