Jeff,
You do make some good points, but if you have a PQR that was qualified on material that was tempered hotter than the PWHT temperature, and then you get some material in that was tempered below the PWHT temperature, based on the different practices employed at the mill to achieve the same properties, there is likely a difference in the chemistry of the material. So at that point you don't know if the properties of the material that has seen PWHT above the previous tempering temperature meet the minimum requirements or not. However, the poster does not say what the condition of the material was that the PQR was performed on. The way I view it, is that the MTR reports what the material's properties are in the heat treat condition that it was supplied in. If the heat treat condition is changed, the MTR no longer represents the material in question.