You can try something like this:
BCP "SELECT concat('""', replace(ColName, '""', '""""'), '""') as comments…
But for efficiency maybe it is better to show your C# code too. Also reconsider the quotename and char(34) functions (https://learn.microsoft.com/en-us/answers/questions/335100/bcp-error-copy-direction-must-be-in-out-or-format.html).