There is another reason that I don't like to see relief valves mounted horizontally. We have a critical pump that has two relief valves on the lube oil system that are mounted horizontally. For these particular valves, the inlet and outlet are the same size. When pipe fitters removed these valves for routine maitenance, they were reinstalled vertically since that is what is most common. A relief valve hooked up backwards will not work. In our case, this was not very serious since it was just a lube oil system. In a more critical application, operating with no overpressure protection could have had very serious consequences.