Yes, except no.
You should be able to assemble my NOFDD program on your machine and run it. I am not sure if this counts as an ‘additional tool’; although it is not a binary that comes with the stock system, it’s also not something you have to download or copy from somewhere else, but a program you can generate yourself entirely on your machine, using only utilities coming with a vanilla Millennium installation.
To get it to run at system startup, you will have to hack the system in the usual way to make it process CONFIG.SYS and AUTOEXEC.BAT and invoke the utility from either (preferably, an INSTALL= directive in CONFIG.SYS).
I suppose writing a VXD driver would be a cleaner solution for that particular version of Windows, but that would be more involved, and definitely violate your ‘no additional tools’ requirement.