NVIDIA driver crashing

I have a Palit GTX 460 Sonic (the one with a crappy heatsinc and no heatpipes and a non-standard screw layout making it near impossible to get a decent cooler for it, growl...) and I constantly get driver kernel crashes in Windows 7 x64. Here's the laundry list of things I've tried or replaced:

-New MSI motherboard
-New RAM (Ran MemTest86+ for over 4 hours to verify the RAM was good)
-New case fans
-New power supply
-Reinstalled Windows
-Undervolted the card
-Underclocked the clock/shader/memory frequencies using MSI afterburner

The weird thing is that it never artifacts or crashes 3D games, it only seems to crash while in "2D mode" while doing Flash/Java based things inside Firefox/Pale Moon/IE9.

To burn-in test the card, I ran MSI Kombuster (Furmark) at 1920 x 1080 (Extreme burn-in mode) for over 2 hours. The core temp of the card got to almost 80 degrees, but it never crashed or artifacted.

I'm kind of against the wall as far as getting RMA assistance from Palit considering in my infinite brilliance (it seemed like a good idea at the time) I removed the heatsinc, cleaned the crap paste they put on the card, cleaned the heatsinc and reapplied using Arctic Silver 5 T.P.. The temp of my GPU came down, but the kernel crashes continued. I've run the video RAM test (this one: http://majorgeeks.com/Video_Memory_Stress_Test__d5896.html) and it found no faults in my video RAM. Does anybody have any advice? (I'm running NVIDIA driver 280.26, however it's happened in the last several beta and WHQL certified drivers released...)
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  1. Also, to add, the card makes successful repeated runs of 3DMark 06.
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