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Also, I doubt that this is applicable in this situation, but nonetheless.
Water can be liquid at 32F, there is a 'grace' period where water goes from a liquid to a solid that requires energy. The 32F water is still liquid and the molecules begin to line up in a crystilline form. If you were to contine to remove energy from this water at a FAST rate, while the molecules are still lining up to crystalize you can super-cool the water well below 32F. Though, the crystallization will catch up and it will freeze solid.
on a side note: google for Super Cooled Water, interesting stuff.
-SF
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