This position seems legal indeed:
The 3 missing black men are enough for the 6 white promotions RBBNNN and then also the 3 black promotions QRN are possible. There must be 1 missing man of the opposing side per 2 promotions on the side with most promotions, so that the pawns can pass towards the promotion square.
That is all right, but your estimate of the number of legal positions would be more accurate if you could eliminate obviously illegal positions at the source instead of after sampling.
Also the upper bound N is relevant in its own right as well as your resulting 153 bit per FEN.
Anyway, I look forward to your results of sampling 1000 and 10000 positions. I guess the real fraction of legal positions will be less than 8% of your present N.