In my opinion, in your case, welding procedure qualification shall include impact testing of welds and heat affected zones.
Further, impact tested consumables in lieu of impact tested welding procedures permitted only if following conditions apply:
1- base metal is exempt from impact testing by UCS-66(g)and that MDMT is no colder than -29C but not colder than -48C or
2- base metal is exempt from impact testing by Figure UCS-66 and that material belongs to curve C or D and that MDMT is no colder than -29C but not colder than -48C.
If base metal is exempt from impact testing by UG-20(f), welding procedures are also exempted.
Javed Nasir
Inspection Engineer
Technip-France Abu Dhabi