I'm in canada, and the code keeps the ground grid between 6" and 24". I beleive if you put it below the frost you may have problems with step-touch potentials. I've dug up a couple of stations installed in this fashion and not seen damage due to frost. Ground rods are installed through the frost, and I haven't personnally seen them pushed out, but perhaps others have. I beleive it is important to get the rods below the frost level for the reason you've stated, but not the grid. I would suggest a review of IEEE 80, "IEEE Guide for Safety in AC Substation Grounding".