best case, run with a das like loheiman did at SFF NAS/Plex Server w/ DAS
otherwise, limited space, cost to get it up and running in a similar form factor of a real nas makes it a wash.
next you can look at the OTIS builds, specifically the recent U-Nas Build, [Official] U-NAS 8-bay Mini-ITX NAS (OTiS - 8th/9th gen Intel) JDM used an 8500t but no reason he couldnt have gone even lower power if he wanted to.
overall, not really a technical limitation outside of just better options out there.