You can achieve that much RAM with 6.5. I have some 6.5 ROMs Titanium that can achieve over 105MB free of Program memory and over 265MB of Storage. I think more to the point, it's harder to achieve this in 6.5 with Manila on top of it although i could be wrong, lol. Nice job on the ROM, and Welcome new TP2 chef
EDIT: I attached a screen shot. This is after 2 days of use, no soft resets, with apps open. 23518 Titanium. It was at 105MB but mymobiler took an extra 3MB lol.