the only questionable part is HDG to MODRO
While MODRO does use the symbol for a fix, the text beside it says "after passing R264 DOL turn left..." Seems pretty clear to me that, practically speaking, MODRO is intended to refer to a line of position rather than a fix. In any case, does it actually matter whether an aircraft maintaining a heading passes over or merely abeam MODRO? Either way it has to turn left to track to the VOR.
Again practically speaking, it seems unlikely that an aircraft without R/T failure would actually get that far on the SID ("after reaching 6000' expect further clearance" etc).
O8