No, Per QW-356, paragraph WQ-403.13 does not apply to welder qualification using the GTAW process. QW403.18 applies, which references QW-423 (P1-P11 qualifies P1-P11 (among others)). So as far as base metal differances between P91 & P22, the welder would be qualified, but other factors such as filler metal (are they both F6?), pipe diamter and thickness, backing, etc. need to be considered (See all essential variables listed in QW-356).