It depends on the characteristics of your camera. For my camera, an Apogee U16M with KAF-16803, I target a total of 500K electrons (which is the point of diminishing returns according to a flat field PTC analysis.) My full well is around 80Ke-, so at an ADU value in the middle of the range that's only 12 flats. If you have a camera with shallow wells it will almost certainly be a much bigger number.
Without doing the PTC calculation, something around 30-40 flats sounds like a reasonable number for a sensor like the KAF-8300 (25Ke- well depth.) You could always use the PI tools to do a noise analysis as you add more flats to your master and see where the improvement starts to drop off.
Cheers,
Rick.