At one point it used triangles for the large splats, and still compute shaders for the small ones due to quad overdraw. I'm not sure if the final version stuck with that or went all compute, but quad complexity is also why nanite does compute shaders for small triangles and traditional rasterization for the larger ones.
But it's a bit difficult to find the exact reason since profilers won't really tell you a concrete bottleneck when drawing vast amounts of tiny tris.
4K has 8 million pixels so should be able to do pixel per triangle with a separate depth pass and still fall within that 20M even with some overdraw from not all patches able to be culled.
edit: opps thought you said per frame, per ms would give 330M/660M triangles per frame, doesn't seem like a big bottleneck; PS4 was more like 26M per frame though but rendered at 900p-1080p. I think it's translucency was stochastic so lots of stuff could still get culled, but wouldn't be able to cull as aggressively (like nanite with masked materials).