If you have the 249 transfer case (Quada trac) then I will almost guarantee you that it is the viscous coupler (VC). I, like many others, had the same identical problem with my 95 ZJ limited.They (the VC) are known to go bad at approx 80,000 miles. The reason you don't hear it all the time is that it is either just starting to go bad, or more than likely you just don't drive it long/far enough to get everything "warmed up" in the t-case. Think about it, does it make the noise more often after you have driven for 20-30 minutes, and not so much when you take a short 5-10 minute drive? The way to check is drive your Jeep at highway speeds for 20-30 minutes, then go to a empty parking lot, stop, turn your steering wheel the whole way to the left or right, then let off the break. If it is the VC, your Jeep will not want to move at idle and/or you will get the noise that you have been hearing.
Problem is that the VC "part" has a cost about $800. And changing the fluid WILL NOT help. You would be better off to go to a salvage yard and pick up a used 249 transfer case, or for that matter do a t-case swap and put in a 242 (select-trac) or a 231 (command-trac). Both are much better t-cases, and you won't have to worry about the VC going bad AGAIN. Ther are MANY write ups on how to do the swap on the internet, do a search NAGCA or Mallcrawlin.com. Jeep Horizons has a great article (with pics) on the 249-242 swap. Like I said just do a search, lots of info available.