I also encountered this problem ,the chip is only used several times. I thinks it maybe a bug in upsd. it seems doen't work and breakdown . after a wrong hex file is programmed!
I've seen this problem with a uPSD3254A as well. I've never had it get to the point where I couldn't recover a chip, however. I seemed to be able to get around the problem by performing a hardware reset (with a wired-in switch) and starting the Program All cycle from flashlink immediately after that. I'd have to fiddle around a bit with it before I finally caught it in time. Also, I determined that it ALWAYS had something to do with my firmware, because I identified certain object files that would cause this problem after programming and others that just wouldn't.
One of my theories at the time was that the chip might malfunction if the watchdog timer was resetting it frequently. Other than that, once I was past the problem myself I didn't have much motivation to look into it further. I suspect, as it seems others do as well, that this is a bit of a glitch with the chip and it's somehow possible to be using/abusing resources within it that it needs for JTAG programming. At the very least, I would say that this is not isolated to the 3233.