It doesn't even have to be during a write operation. Nand needs to be periodically refreshed after a read, so the controller can be shuffling data even on a read-only mounted card. I've read speculation that most consumer cards store their controller firmware on the same nand that is used as the general storage, and thus are prone to corrupting their own firmware if something goes wrong while shuffling data.
Power loss is definitely a threat to an SD card in a Pi. But I've seen many cards go bad while the system is still running, so it's not the whole story.
Weirdly, I've had a number of cards that entered a state where they would be inaccessible under Linux or Mac OS. But they could easily be recovered by a re-format under Windows. No idea why. Perhaps the manufacturers test a lot more thoroughly with Windows?