The code is not clear exactly how to figure this out. For one, there are several wiring configurations in which a 500A circuit can be supplied. Here's one way to do it:
Calculation:
Assume you really only needed 800 kcmil of ungrounded conductor for the 500A circuit. You are installing 2,500 kcmil. This is a 3.125 increase. (2,500,00 / 800,000).
A typcial 500A circuit requires a #2 AWG EGC. #2 = 66,360 cm X 3.125 = 207,375 cm = 250 kcmil EGC.
So, the cable tray may serve as the EGC (250.118 / 392.3 / 392.7) or 1 - 250 kcmil copper EGC (250.122(B).