Yes, easily, either use PHP to read all files in the photo folder and load (build array to keep track of where you are), or use a table with admin upload and maybe links and description if needed inserted into db, then script to retrieve pics, could even add an un/publish column and use that to select and return list of pics to load to Flash.. basically, anything you can do with PHP, you can send into Flash, just strip the markup/css/html and use Flash as frontend..
Is there interest in such a module/component? I have no idea about the backend tho', and it would be my first shot, so I guess I would just take an existing one and tear appart the code, use what I need etc.. and it would take a while

If anyone good with PHP wants to collab, I can get the FLash ready, tell you what data I'd need depending on specifications set for the mod_ or com_ , and then get a hand on the script / admin side..?
Table in db, no table (just read from folder), admin: what can be done here (ie: upload, delete, add comment, publish/unpub., ...)... losts of stuff to work on.