I think there is some confusion here. the 820D is the merlin plus (the tall one with line cards for 4 COs each and station cards for 10 stations each)

The Merlin plus does not work without a grey feature card in the top of it.

The Merlin 820 (without the D) also known as the Merlin classic has 2-0 2-5 or 0-5 cards in it. It can work without a feature module but a feature module is required for the intercom to work. Only a Feature pack 2 will work in an 820 .

All of the websites do not mention intercom as a feature of the feature module but I remember that it was. I will check an old AT&T sourcebook catalog later in the day.