A watercooled peltier couldn't do it, I'm pretty sure. You would need a very powerful peltier, and there isn't a good enough watercooling system to cool that powerful of a peltier.
Got it up to 3.3/275FSB 5:4 div. last night. I had to up vcore to 1.575 and temps were too high, and it was still pretty unstable. Ill try and tweak it to run stable at that. Its at 3.0/250FSB 5:4 1.55 vcore right now, and its stable. I probly wont keep it like this. Ill lower it to 2.8/233FSB 1:1 div. and tighter timings, so itll perform 2x better then guinnys 3.0:afro: