Cabletray vs Raceway

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I understand that the code does not consider cabletray to be a raceway and therefore the cable needs to be cabletray rated. If I was to add a bottom and ventilated top to the cabletry could I then consider it a surface raceway per code? The problem I have is some 15kV cabling was installed in tray that is not CT rated and I'm looking for a solution rather than replace all of the cabling.

Thanks,
Tim
 
IMO you cannot do what you've suggested since the conductors would need to be installed within a listed raceway. Making you're own raceway would not have any listing. IMO it might be better to try and install a listed raceway within the cable tray and pull the condcutors into that.
 
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