The 421A (and the 5998 ) has a higher mu than the 6080, so the hair trigger volume control thing that happens when you have a high level source or sensitive headphones will get worse. Ditto subbing a higher mu tube for the 12AU7. A lot of folks who are used to SS circuits mention hearing a little noise when the volume control is turned way up with no signal present, like to a setting way louder than one could ever really listen with music playing. That's just the nature of tubes with no feedback, a compromise necessary to get the good stuff that tubes offer. What we seek is to get a dead quiet background at what would be considered a very loud but not damaging listening level. Crack can definitely damage your ears (and your cans if they are reasonably sensitive), the source level is high, and you peg the level control.
One could try a shunt attenuator. It gives you the voltage divider for attenuation that you are looking for and allows you to set up the components so that the pot is just a variable resistor that is shunting signal to ground and you can use a high zoot resistor as the series element (that the signal passes through to get to the tube's grid).