Yes, it is, but it would be better with more variety in vocabulary. Using the word "cold" three times is two times too many. What words can you use besides "cold"?
Yes, the phrase "Feeling the cold air that is as cold as the cold words" is an example of a simile. A simile is a figure of speech that makes a comparison using the words "like" or "as." In this case, it is comparing the coldness of the air to the coldness of the words that were said. Similes are often used to add emphasis or vividness to descriptions.
