Eligible expenses would be things like costs directly related to the purchase or construction of a primary residence, including building materials and closing costs. Not a moving van since that has nothing to do with the purchase of a principal residence.
If the plan is terminating, and participants are making these elections to roll into the 401(k), then the in-service rule in the DB is irrelevant, and further, none of the DB distribution restrictions or characteristics follow through to the 401(k). If the 401(k) permits in-service at 59 1/2 then that is what applies (and some plans allow rollover money to be withdrawn at any time; that would apply as well).
I think EPCRS is the wrong place to look. You made QNECs to correct a testing failure. Those accounts now exist and are subject to all plan terms and conditions. If these participants are otherwise entitled to a distribution*, and the fee eats up their money, so be it - pay them out at a net $0 and move on.
*Maybe I'm reading too much into it but you may not just get rid of accounts for active participants because they are small accounts.