This is from Velan service Manual for Check valves.It mentions 10 pipe diameters.
All piston and ball check valves should be installed
in a horizontal pipe run with the cover up, and the
angle of incline of the line should be no more than
45° from horizontal. Also, the roll angle of the valve
cover should be no more than 45° from side to side
(Figure 2.5D). For vertical flow condition, please
consult the Velan Customer Service Department.
Swing check valves should be installed in an
horizontal, inclined or vertical position. The roll
angle of the valve cover should be no more than
45° from side to side (Figure 2.5C).
NOTE: All check valves should be installed at
least ten pipe diameters away from upstream
pumps, elbows, fittings or equipment. If closer
installation is required, please consult the
Velan Customer Service Department.
WARNING: Soft-seated piston and swing
check valves should not be welded into the
pipeline with the soft-seated disc in the valve.
The disc must be removed and reinstalled after
the valve is welded into the pipeline.