Hi Neil,
sorry for the delay in the response to your question. Bear in mind that the shell is seeing circumferential stresses due to pressure (see UG-37, definition of tr), whereas the flat head is seeing bending stresses. I believe that it is the intent of the code that one should not "mix" stresses. If you refer to UG-37 & UG-39, there are completely different rules for the reinforcement of openings in "shells and formed heads" and for openings in "flat heads". I agree with prex, you could use U-2(g) to try to justify your method. The solution I gave is by far the easiest to justify in terms of my understanding of code rules, however that is not to say it is the only solution. One could revert to the use of FEA, for instance, however one would need to weigh up the costs of the additional calculations vs the cost of extra material. Unless the thicknesses you are using are very close to the required thicknesses for the components, then the additional material costs (if any) may not justify the use of a more complex design tool. Why not have a chat to your AIA, I'm sure they would give you some guidance also.
John