With good cooling, maybe. You'd have better luck getting a brisbane and trying to take it there. Many many people are hitting 3+ with the 3600+. A high end brisbane, good mobo, and a great cooler may get you above 3.2
I saw a review claiming they got to 3.6 but didn't see any evidence like a cpu-z or something so not sure. If it can go above 3.2 it seems the limit would be like 3.6 on water or phase.
Lots of the brisbane guys are getting there. Shoot, mine would make it to the splash screen at 2.9Ghz on the stock cooling. I would think with an excellent air cooler and a slightly better mother board... 3.2 or better is possible.
I don't have linkage right now, but I'll see what I can dig up