It turns out that the PB2 line in PORT1 is actually used. When it's set, the U2250 PAL stitches together the 3 "lost" 8k sections of the two ROMs to create a 5th 24k bank.
The loader should be able to cope with this by looking for a pair of 5370/5371s and stitching up another overlay memory block from the right pieces.
Looks like backing the memory blocks with FileBytes is the right approach. This allows accessing the full contents of the file after the initial memory blocks are created.
It turns out that the PB2 line in PORT1 is actually used. When it's set, the U2250 PAL stitches together the 3 "lost" 8k sections of the two ROMs to create a 5th 24k bank. The loader should be able to cope with this by looking for a pair of 5370/5371s and stitching up another overlay memory block from the right pieces.