VPI Immingham OCGT

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VPI Immingham OCGT

Received 25 June 2019
From Phillips 66 Limited

Representation

Applicatio: DCO for VPI Immingham OCGT Planning Inspectorate Reference: EN010097 Applicant: VPI Immingham B Limited S.52 Letter:Letter from the Applicant under S.52 of the Infrastructure Planning (Applications and Prescribed Forms and Procedure) Regulations 2009 Works: The works identified as Works no’s 1 -6 in the S.52 Letter. Existing Arrangements:A lease of the VPI Immingham Power Station, a lease of car parking and lease of the Existing Gas Pipeline Site all entered into between Phillips 66 Limited and VPI Immingham LLP as amended and varied. Representation Phillips 66 Limited (Phillips) own and operate the Humber Refinery which sits on a 480-acre site at South Killingholme on the Humber Estuary. Preliminary Statement Phillips are currently in discussions with the Applicant to agree a position acceptable to both the Applicant and Phillips to enable the Works to be carried out within the framework of the Existing Arrangements and to enable the Applicant to benefit from the rights currently existing for the benefit of VPI Immingham LLP (VPI). The Applicant, together with VPI, has made a proposal to Phillips in this respect which is currently being considered by Phillips. Phillips object to any Works which have the effect of increasing or adversely affecting the COMAH (Control of Major Accident Hazards) risk profile of the Humber Refinery. Comments on the Works 1 Work No 2 Access routes are contained within land let to VPI under the Existing Arrangements. Consent will be required under the Existing Arrangements to Work No 2 and appropriate amendment to the Existing Arrangements to enable the Applicant to carry out the Works. Phillips oppose any acquisition of the land for Work No 2 as the Applicant has indicted that, with amendment, these works can be carried out under the Existing Arrangements. 2 Work No 3 Land required for Work no 3 is again let to VPI under the Existing Arrangements. The comments above relative to Work no 2 are repeated and P66 oppose any acquisition of the land. 3 Work Nos 4, 5 and 6 3.1 Phillips operate 3 pipelines (the Pipelines) on land required for these works. The pipelines are a continuous operation for the passage of multi-purpose hydrocarbon fuels. The Pipelines run above ground. 3.2 Phillips oppose the acquisition of the land and consider that the consents for these works could be documented as ancillary to the Existing Arrangements. 3.3 the Applicant must not interfere with or damage the Pipelines or interfere with, impede or obstruct Phillips' access to them. 3.4 agreement of a method statement for working and supervision within the vicinity of the Pipelines is required before any work commences; it is essential that the safety and the integrity of the Pipelines and those working on the Pipelines is taken into account during the construction process. 3.5 access to the Pipelines is required at all times both for routine maintenance and emergencies. 4 Work to the Existing Gas Pipeline, as referred to in the S.52 Letter Phillips oppose the proposed acquisition of the Existing Gas Pipeline Site. The gas pipeline runs through Phillips’ operational land and any further sterilisation of that land would have a serious impact on the business operated by Phillips at the Humber Refinery. No alterations are to be made to the pipeline and it is considered that use of the pipeline can be accommodated within the Existing Arrangements. Phillips 66 Limited 25 June 2019