Well said.Any additions must conform to current code. If the house wiring had to conform to current code when a wiring addition was done, most houses in this country would have to be rewired when something was added. And adding this spa panel to a unused stove circuit is adding to existing wiring.
Just another prospective: If the Spa panel is installed as a plug in device, the building wiring is not altered at all. Therefore no inspection required and no violation of any code.
Almost every dryer or range is a 240 + 120V device. Through about 2007 the power feed was done using a 3 wire feed.
Just saying.