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With ZERO case air flow though other parts will also get hot. It might be ok if the case has a lot of air holes so the heat can move out on its own. Maybe a lot of mesh etc... A typical case with just a couple fan holes will be an oven.
This is doable with a large heatsink and severe underclocking/volting. As long as the room where this is kept is reasonably cool (no shoe closets), it should be okay running around 800Mhz and down to 0.6-0.7V. It would be much easier however, to just add 1 very slow moving fan. Any air movement helps a lot.