GFCI Protection in a Kitchen Remodel with Old Wiring
A 1970s single-family dwelling kitchen is being remodeled. The existing branch circuits are two-wire (no equipment ground) NM cable. The remodel adds a new 20 A small-appliance branch circuit, a dishwasher circuit, and a 240 V range circuit. The electrician proposes to extend the existing ungrounded circuits to new countertop receptacles and to install GFCI receptacles at the first outlet on each existing circuit. The inspector flags the plan because the new countertop receptacles are on circuits that also serve the dining room, and because the dishwasher is cord-and-plug connected under the counter. The homeowner wants to avoid rewiring the whole kitchen.
1. Can the existing ungrounded circuits be extended to new countertop receptacles, and what protection is required?
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Under 406.4(D), replacement receptacles on ungrounded circuits may be GFCI-type, and 250.130(C) permits extending an ungrounded circuit only if the extension is protected by GFCI and the receptacle is marked 'No Equipment Ground.' However, kitchen countertop receptacles must be supplied by the two or more 20 A small-appliance branch circuits required by 210.11(C)(1), and those circuits must not serve other outlets outside the kitchen (210.52(B)(1)). Extending an existing general-purpose circuit that also feeds the dining room to countertop receptacles violates the small-appliance circuit requirement. The correct approach: run new 20 A small-appliance circuits from the panel to the countertop, GFCI-protected per 210.8(A)(6), and do not extend the old dining-room circuit to the counter. The existing ungrounded circuits may remain for their original outlets with GFCI receptacles marked 'No Equipment Ground.'
2. What GFCI and connection requirements apply to the dishwasher, and does the cord-and-plug installation change anything?
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Dishwasher receptacles in a dwelling require GFCI protection under 210.8(A) (kitchen areas) and, where within 6 ft of a sink, additional consideration under 210.8. A cord-and-plug-connected dishwasher must have the receptacle accessible and GFCI-protected; the cord length must comply with 422.16(B)(1) (typically 3–4 ft) and the receptacle must be located to avoid physical damage. If the dishwasher is hard-wired, GFCI protection is still required for the branch circuit in a kitchen. The inspector's concern about cord-and-plug under the counter is valid if the receptacle is not accessible - 422.16 requires the receptacle to be accessible without removing the appliance or cutting the cabinet. Recommend a GFCI receptacle in the adjacent cabinet or a hard-wired connection with a GFCI breaker.
3. The electrician wants to use the 240 V range circuit's neutral for the new 120 V countertop receptacles to save a run. Is this permitted?
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No. Using the neutral of a 240 V range circuit to supply 120 V countertop receptacles creates a multiwire branch circuit or an improper shared neutral and violates 210.4 (multiwire branch circuits require a common disconnect and handle-tied breakers) and 210.11(C)(1) (dedicated small-appliance circuits). The range circuit is a dedicated appliance circuit under 422.10 and cannot serve other outlets. Additionally, the neutral must be sized for the maximum unbalanced load, and tapping it for general-use receptacles risks overloading the neutral and defeating GFCI protection. The correct solution is a new dedicated 20 A circuit.