Don,- While there is no direct code section stating we can install the electrode system as I said, there also is no wording that says I cannot. Basicly we are using 250.52(A3&4) without the concrete. On our larger services we use 2,3,&4/0 copper. Our AHJ's have no problems with these installations. Don't get me wrong, I do use ground rods 90% of the time.
