I'm having the same problem with crashes on Cue.Apply3D in the Audio3DWindows sample that comes with XNA.
Everything worked fine on my laptop with a 2-speaker configuration, but when I moved the code and ran it on a surround setup the Apply3D method crashes with the ArgumentException "Value does not fall within the expected range."
The Apply3D method accepts a listener and an emitter. The listener has values: Forward={0,0,-1}, Position={0,512,0}, Up={0,1,0}, Velocity={0,0,0}. The emitter has values: Forward={0,0,-1}, Position={0,0,0}, Up={0,1,0}, Velocity={0,0,0}, DopplerScale=1.0.
3D sound is kinda useless if it crashes on setups with more than 2 speakers!!!