From MSDN on LoadLibrary() (emphasis mine):
The system maintains a per-process reference count on all loaded
modules. Calling LoadLibrary increments the reference count. Calling
the FreeLibrary or FreeLibraryAndExitThread function decrements the
reference count. The system unloads a module when its reference count
reaches zero or when the process terminates (regardless of the
reference count).
In other words, continue to call LoadLibrary() and ensure you get your handle to ntdll.dll
to be safe -- but the system will almost certainly be bumping a reference count as it should already be loaded.
As for "is it really always loaded?", see Windows Internals on the Image Loader (the short answer is yes, ntdll.dll
is part of the loader itself and is always present).
The relevant paragraph is:
The image loader lives in the user-mode system DLL Ntdll.dll and not in the kernel library. Therefore, it behaves just like standard code that is part of a DLL, and it is subject to the same restrictions in terms of memory access and security rights. What makes this code special is the guaranty that it will always be present in the running process (Ntdll.dll is always loaded) and that it is the first piece of code to run in user mode as part of a new application. (When the system builds the initial context, the program counter, or instruction pointer is set to an initialization function inside Ntdll.dll.)