Well that's an unfortunate figure to get!!
Smack on the limit of what is classed as an extraneous conductive part (ECP)
I believe the resistance to earth of the suspected extraneous conductive part should actually be greater than 22K ohms between the suspected ECP and the MET of the CU (or nearest known verified connection to earth) (i.e 0.022M ohms), therefore yes, it is an ECP. Also, from certain literature I've read you could add on a factor of safety, bringing the value up to perhaps 25K, meaning your suspected part is definitely ECP.
It's a bit odd how it can test as low as 22K though, as you can clearly see both pipes being fed by plastic. Are there any other metal pipes coming off from those pipes, perhaps going straight into the wall, maybe hidden behind the insulation of the pipes?
Also, I cant see where your leads are attached to. What have you got the 2 leads attached to? Just noticed you say one end is attached to the CU. If the Cu is painted or has some kind of coating, this will affect the result drastically. I'd be opening the CU up and attaching to the MET (as long as you are an electrician).