Pennpiper's good answers illustrates 'the engineers' way of thinking: what practical issues must be considered before any decision is made?
On the other hand: is there anything else either hindering or making it necessary with a top placement of an ERV?
Constructionally I cant think of anything, apart from special local construction details or surroundings, that could prevent a top placement of an ERV.
The direction of the release from ERV (either pipeline or free, or if the ERV is a bursting disc) could, under circumstances, favor a top placement.
I do no know if API 650 directly forbid or prevent top mounting, but I do not think European regulations prevent this. If you remount a complete vessel with a side-mounted ERV by turning it 90 degrees and lay it on its side, I do not believe you have to move the ERV, or rotate the tank to make the ERV side-mounted.
Or am I wrong?