boulders bonded?

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I did an inspection a few weeks ago on a pool. It was to check the grid for the deck around an in ground pool. The #8 grid was made up for the concrete deck but only went about 2/3 around the pool. On the deep end of the pool were several boulders setting right on the edge of the pool. Several were stacked up to form a wall. A closer looked revealed that the boulders were setting on concrete. My thought was that these boulders are going to be climbed on from the water of the pool and can easily be touched while in the water. I red tagged it stating that the bonding grid should be installed under the boulders, they are certainly within 3? of the edge of the pool. I feel the boulders are every bit as conductive as dirt. My boss says that the code only says that it should be under walking surfaces, and that nobody should be climbing on the rocks. Any other thoughts?
Thanks in advance.
 
I don't see how this could be considered a paved walking surface. Your boss was correct.

680.26(C) Equipotential Bonding Grid. The parts specified in 680.26(B) shall be connected to an equipotential bonding grid with a solid copper conductor, insulated, covered, or bare, not smaller than 8 AWG or rigid metal conduit of brass or other identified corrosion-resistant metal conduit. Connection shall be made by exothermic welding or by listed pressure connectors or clamps that are labeled as being suitable for the purpose and are of stainless steel, brass, copper, or copper alloy. The equipotential common bonding grid shall extend under paved walking surfaces for 1 m (3 ft) horizontally beyond the inside walls of the pool and shall be permitted to be any of the following:
 
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