I figured this out.It's partly that C3D 2016 assumes attached data is in International feet, and a TBC export setting.
Using C3D 2019, with the attached data setting set to US Survey Feet in the "units" command, and export from TBC with the scaling option in the export RCP format as "grid" instead of ground even though I've scaled my data using Local Site Settings, then it attaches in C3D 2019 in the correct position.