I used the bullet metrics wizard in QL and allowed that most of the .38 Special cases I see have about 1 grain more water capacity than the QL default. I ran it with both the W231 and HP38 models, as these powders are actually the same thing in real life (canister grade St. Marks OBP231), but Herr Broemel measured two different lots for the QL database that had slightly different characteristics, so running both provides a degree of the spread you might expect. I got 48,731 psi for one and 50,396 psi for the other. It looks like the maximum for this powder is about 2.6 grains for SAAMI .38 Special spec with a magnum primer and 2.9 with a mild primer, and 3.0 grains for CIP .38 Special spec, and 3.2 grains for CIP with a mild primer.
It should be pointed out that QuickLOAD has no primer argument. As the author explains, magnum primers can sometimes raise pressure, but sometimes lower it, depending on special circumstances, so the program just assumes the mildest possible primer. I have seen everything from no-change to and increase in pressure with magnum primers of about 10%, so I added 10% to allow for a worst case magnum primer.