In light of reporting the BOTH a TODA and a TORA, I will conjecture that the TO may have been perfectly OK...depending upon what was the limiting case AEO/OEI and the size of the TODA [remembering that this is a quad---for first segment considerations of the OEI case] ----and also observing that Vlof was achieved by the end of the runway then
--either---
1. the margin on the AEO case was contained within the clearway
2. the OEI case was predicated on a clearway---but at the end of the TODA ---but how much of the APRT boundaries were declared a clearway?
we simply don't have enough information to conclude anything regarding the legalities of that TO other than that it looked interesting!