Old thread, but just in case the OP still wants an answer . . .
I recently bottled a Belgian Tripel with half the batch at about 3 volumes in regular beer bottles, and half of the batch in at a little over 4 volumeschampagne bottles/begian 33cl bottles, and a few sam smith cider bottles. They have been conditioning at a relatively warm 74 degrees for the past month with no sign of problems. I opened a bottle of the 3 volume tripel two weeks ago and it was fully carbed, so I expect by now the 4 volume stuff is fully carbed, too. I'll revise this if I have any issues, but so far it appears safe to go to at least 4 volumes in these bottles.