Any processor with many threads will get hot when all those threads are fully loaded.
Fortunately, when gaming, that is not the case, like it would with heavy multithreaded batch processing.
I use a noctua NH-D15s and a i9-12900K.
Running the simple CPU-Z stress test, I do see a couple of threads reach 100c.
But, the processor keeps on trucking.
In normal use, I see nothing remotely like that load.
Normal turbo takes into account and does the best it can with whatever cooling you have.
It is a much better option than all core overclocking, in which case only a 360 aio or better is what you would want.
If you have a well ventilated case I would think a good air cooler would be as effective as a 280 aio.
Air will be quieter, cheaper, more reliable, and will not leak.