TonyTao, you ask if there is a Code Interpretation to support the view that impact testing is required, this is not necessary because the Code states the requirement explicitly. See UHA-51(a), "impact tests shall be performed on all materials listed in Table UHA-23 for all combinations of materials and MDMT except as exempted by UHA-51(d), (e), (f), (g), (h), or (i)."
UHA-51(d)(3)(a) provides some exemptions from impact test for austenitic ferritic duplex. However, from your description of the material it is not exempt, as based on thickness and need structural integrity. Because it is not exempt, impact testing will be required per the main paragraph.
You may be able to exempt with UHA-51(g) as based on low calculated stress ratio.