To Clarify;-
Built up back pressure can be as high as overpressure value, with conventional, spring operated pressure-relief valve.
For superimposed variable back pressure, a balanced spring operated pressure relief valve is necessary.
Ref. API Standard 520 Part I (Oct 2020). Section 5.3 Backpressure
The '10% backpressure' statement is largely misunderstood. Generally you can use a conventional spring pressure relief valve with up to 10% BUILT UP backpressure, where overpressure is 10%.
ANY variable, superimposed backpressure, requires a balanced PRV.
*** Per ISO-4126, the generic term
'Safety Valve' is used regardless of application or design ***
*** 'Pressure-relief Valve' is the equivalent ASME/API term ***