Is this a motor fueling LNG facility? If not then I don't believe 514 applies.
Does the hazardous area actually extend below grade?
Although I would question the cost savings, I believe what you are describing would be allowed by 501.10(B)(1), which references 501.10(A)(1), if you are 24" below grade and encased in 2" concrete. Proper bonding would be required per 501.30.[/QUOTE
Prior to the 2005 code, the ground was classified as Division 1 for the first two feet underground. Now its shown as nonhazardous.
Even though the installation wouldn't be described as motor fueling per se, I believe article 514.3(B)(1) still applies. This plant has many outdoor pumps, some installed near LNG storage tanks (see table 514.3 (B)(1). Also if I'm reading correctly, 501.10(A)(1) requires threaded rigid metal conduit for the last 24 inches of underground run or the point of connection to the aboveground raceway. Even though the conduit will be almost entirely buried (except at the stub-up) its still electrically discontinuous, i.e. below grade the RGS elbow will be floating, which in real-world terms probably isn't a big deal but I still see it as a code violation.