FenderBender nick wrote According to the amp schematic, one tube should be as 12at7 That would be the phase inverter, closest to the power tubes. The 12AX7 in that position is the reason you had so little headroom. I'm stoked you found the problem!
FenderBender Just for reference: ECC81/12AT7 - gain approx 60 ECC82/12AU7 - gain approx 17 ECC83/12AX7 - gain approx 100