I've had three 240s all show the intermittant, spontaneous shift-down (out of OD) syndrome. Two of them, an '84 and a '93, did it for a bad relay. But one of them, an '83, had worn wiring (compromised insulation) underneath, near the transmissio's solenoid. Such wiring faults can be intermittant, just as a failing relay.
It's really a matter of checking both possibilities -- easiest, though more costly (if you don't have a spare relay), being first a swap of the relay (because I don't enjoy crawling under the car around a greasy transmision :-).
I should say, not for this problem but for the sake of any readers, that I also had another case of bad wiring in my other '93, but this was just under the shift cover (an unusual place, as most "worn wiring" is in the insulation and occurs under the car).
There's a metal clip that holds the pair of white wires tight against the shift lever as the wires come out the tube that is the shift handle. This clip has a very sharp edge, and not only cut into the insulation but actually severed the conducters inside. The symptom of this was intermittant loss of control of the OD-lockout function. Sometimes the switch would work, and sometimes it wouldn't (actually, it usually didn't work when the shifter was in 2nd, whereas it usually worked when it's in Drive). What was happening was that, depending on the position of the shift lever, the thin (~24 or 25 ga.) conductors inside the wire insulation was either able to touch (make contact) or not.
I had to solder together the severed ends and wrap them -- I also repositioned the wires so that they would be held in place (in spite of the shift lever's movements) without using the darned clip.
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