George regardless of your profession this is an NEC forum and if you are not basing your response on a code section you should state plainly that you response is an opinion.
People come here to learn the NEC.
FWIW It is possible to fully load twenty 120 volt 2 wire circuits from a 200 amp 240/120 service. Therefore you could have 40 fully loaded current carrying conductors in a single raceway.
Just My Opinion, Bob
Bob Badger Construction & Maintenance Electrician Massachusetts
