How should transfer of spent solutions be reported on Form R?

Form R Reporting for Offsite Transfers of Spent Solution

Under EPCRA Section 313 (40 CFR Part 372), a covered facility is required to report all releases and waste management activities involving toxic chemicals for which the facility has exceeded an activity threshold. A covered facility uses a solution containing nitric acid to strip elemental nickel from plating racks. During the stripping process, nickel nitrate is manufactured in the solution. When the stripping of the racks becomes inefficient, the spent solution (containing nitric acid and nickel nitrate) is sent off site to a facility that recovers the nickel, then treats the remainder of the spent solution and ultimately discharges the treated stream to a POTW. What activity thresholds apply to the nitric acid and nickel nitrate? How should the transfer of the spent solution be reported in Part II, Sections 6 and 8 of the Form R?