I just had a foam volcano in my 6.5 gallon carboy, which was filled to exactly 5.25 gallons. The previous batch was almost at an identical level, but gave no issues. I did a starter this time with a different yeast, and it was nuts.
I didn't own a blowoff tibe, and had to do an improvised one with my siphon hose and the nipple of the airlock. I think I'd have had to do it with a 4.5 gallon batch... this thing was insane (it blew the airlock several feet away).