Would you not be better to confirm that heat treatment is mandatory before looking for loophole in asme ix,has the code you are working to determined that pwht is required,or where is there a spec break between piping and tank? what is wall thickness of pipe,does owner requirements call for pwht regardless of thickness or does it give exceptions,if PWHT is not required then, i think i am correct in saying that there is no need to qualify a procedure
If it was for process piping alone, for example,ASME B31.3 table 331.1.1 for P3 alloy steels,equal to or less than 1/2% cr, equal to or less than 19mm, equal to or less than 490KPa/71ksi, no heat treatment,for P4 alloy steel material, equal to or less than 13mm, equal to or less than 490KPa/71ksi, no heat treatment is required, same table for P5A,5B, 5C equal to or less than 3%Cr/0.15%C, equal to or less than 13mm, all MPa/ksi. no heat treatment is required.
Also Para 331.1.3 gives governing thickness criteria for pwht on branch connections, fillet welds, external non pressure parts etc.
Maybe someone else can give you their opinion as well as this is only my interpretation, but i tend to agree with Pan and look at reason for using this class of pipe,hope this helps