It could be an issue with Windows Remote Management service itself.
There are couple of threads in Microsoft comunities describing similar issue after upgrading to 3.0.
Invoking PowerShell script with PowerShell Remoting feature could cause outOfMemory exception on some systems.This exception could apper because of a bug in WinRM service causing value set for MaxMemoryPerShellMB to be discarder.
You can check for more details following thread WinRM : quotas setting ignored since KB2506143