Louis, you might be okay in regards to section IX as you have specified in QW-407.1, but you should also consider if ASME Section VIII, Div 1 is applicable. In that case, see Table UHA-32-1 which lists a minimum temperature of 760C, with the exceptions listed in Note (a).
Also consider that your proposed temperature differential is significant, and where impact testing is required, you should attempt to stay within the parameters of the qualification of PWHT, especially noting that the hardness of this material will be affected by a different temperature. That is the purpose of the statements found in Section IX, QW-200.3 and QW-421.1(a)
“The assignments do not imply that base metals may be indiscriminately substituted……”
If I were your customer, I would require the qualification test to closely match the production parameters for those reasons.
The devil is in the details; she also wears prada.