The "trump card" is Section 510.2. Articles 511 through 517 override the general rules of Articles 500 through 504 when the installation is within the scope of Articles 511 to 517.
This is an unfortunate case where two Technical Committees (TCs) may not entirely see eye-to-eye and the coordinator in this case is not the NEC Technical Coordinating Committee (TCC) but the NFPA Standards Council (SC). Again unfortunately, the SC often does not always have the integral technical competence to judge the conflict without a long drawn out process – these are some VERY smart folks that just don’t usually have the requisite experience for such judgment.
A large portion of Article 513 was originally extracted from NFPA 409-2011, Standard on Aircraft Hangars. Code Making Panel 14 (CMP14) usually considers grade the boundary and the underground unclassified. Several of the TCs that provide the extracted material for Articles 511-517 have a different opinion.
Personally, using the last sentence in Section 510.2, if I were the AHJ, I’d permit your installation as described. But in the interest of full disclosure, I’m heavily biased toward CMP14.