This is entirely possible, but it's somewhat of a pain.
First of all you need a way to read files off the NAND via arm9 - this definitely possible, but difficult when you consider the space limit of k9lh payloads.
You'd then need a payload that's small enough to fit in the NAND (smaller the better, mainly for DSiWare and stuff). In addition, it would need patches for FIRM write protection at the very least, and would need to be able to load firmware.bin from NAND. SaltFW works perfectly for this, as it is relatively lightweight and contains necessary patches. Another option would be Mizuki.
Like I said, it's possible but a pain. Most developers aren't going to be working on it given that it's relatively low priority as few people boot without an SD card. I would be looking into it if I had a hardmod, but since I don't I'm too afraid to brick
