big sorry, late reply. Uhm, "low mem"? I don't exactly understand what you do refer here. Maybe lowmem memory zone a.k.a ZONE_NORMAL?
But anyway, in general, memory could be used up (until the last drop). This is especially true when you do it in kernel mode. Nothing stops you in this case, because (Linux) kernel always trust itself. Of course, any sane kernel developers should catch this quirk at the first place before releasing any stable releases.
And..about user processes which allocate kernel mode memory. Actually, implicitly you already do that everytime. When you start a program, the kernel also allocates small amount of memory to store its task descriptor. When you're doing system call, usually some user memory content are copied to kernel memory area before further processed.
There is a more explicit example , assuming you know a bit about sound programming. IIRC if you prepare a PCM channel and ask for some amount of buffer, actually you are requesting kernel mode pages.
I hope it clarifies your doubts.