It only does when you use the onboard graphics (included in your processor). Just tested this yesterday. I have 3x 280x (Dual-X) running and 4GB memory is enough without getting any HW errors. As soon as I allocated memory to the onboard GPU (just to make it work), one of the GPU's stopped because of low mem.
So I'm guessing you need 4GB of RAM per 3 280x's.
And what settings do you use? Alot of people suggest 1000/1500 clock speeds. 8192 TC w256. but my GPU1 always gets HW. changing the TC more then 8191 or 8193 gives me huge amounts of HW, reductions in I kills the kh/s. really no idea what to do next
1000/1500, 8192 TC and w256. Exactly those settings give me +/- 360 KH/s. Sorry I can't help you any better

I got rid of the HW errors after deleting all .bin files and use these 2 lines in the config:
setx GPU_MAX_ALLOC_PERCENT 100
setx GPU_USE_SYNC_OBJECTS 1