Martin,
FLOP2PC and PC2FLOP directly access the disk controller to perform disk IO independent of CPM or other operating system. The only way I could write PC2FLOP and FLOP2PC for this particular hardware would be to disassemble the CPM BIOS and/or the 2K PROM you mentioned earlier in order to figure out how to use the disk controller.
If you want to assume you’ll always have at least one bootable CPM disk, then a version of FLOP2PC and PC2FLOP that uses the CPM BIOS for disk IO could be written. Note that this solution would have to be repeated for QMOS or other non-CPM disks you might have.
Mike