It has happened in the UP before, up the hill behind Christmas (these tracks are abandoned now) around 1990 or so. Where the trail crossed the tracks and it was a warm day with plenty of slush. That night a couple inches of slush froze solid across the tracks. When the train hit it in the wee hours at 30 mph it jumped the tracks and jacknifed the two locomotives, made quite a mess. It is surprising this can happen given the weight involved but hard packed ice is all that is necessary to run the wheel flanges off the track.