I don't know what a "white box" reimplementation is (white-box cryptography?) but I guess you meant a clean room implementation (https://en.wikipedia.org/wiki/Clean_room_design) which I believe this is not the case here (I am wild guessing though). For a clean room implementation you need at least two guys, one reverse engineer who writes down his findings and a guy who takes that information and reimplements the same functionality according to the information the reverse-engineer provides.

But you are right in that it uses the same algorithms, structures and control flow as the real Turbo Pascal and therefore should be bug-for-bug compatible but is written in Pascal instead of assembly.