No, three pounds will hold it open with no plate flutter.
The name of the bulletin is oil leak for a reason.
The plate in the spring double seal assembly has rubber on it. There is also a valve stem umbrella type seal further back on rod.
Without ten pounds th rubber seal on plate does not seal properly and the whole assembly becomes askew and start shifting and rocking. The disc that has large cup seal on it that the oil pressure acts against must be kept centered and square as much as possible because there is no centering bushing on outlet of hydraulic cylinder due to the arcing radius the EBV linkage tab travels during activavation and release.
So to recap:
Unstable seal arrangement on two of the three seals in that assembly inside of cylinder.
The front plate needs to be pushing hard against front wall of cylinder or it can not seal.
This assembly needs to be pushing hard against front of cylinder to keep rod and seal plate assembly centered so the back large cup seal that the oil pressure acts against is not tilting so when it DOES rock due to arc radius travel it does not tilt so much that it's very shallow cup seal lips do not allow pressurized oil to rush past them.
This is how it works and is why they want ten pounds, hence the name TSB oil leak.
Makes me glad I took the time to preload mine when I changed out the turbo. It wasn't leaking and I didn't really want to tear into it so I just change the outer seal and set the preload as per the kit instructions, 10 or 11 lbs IIRC. No leaks yet.