MOD 6 Chlorine Liquefaction Plant

I am a resident of Jennings Street, Matraville, living in close proximity to the IXOM Botany/Matraville facility. My home is within walking distance of the proposed chlorine liquefaction operations.

This proposal poses direct risks to my household’s health and safety. Any accidental release of chlorine would place us in immediate danger. We already experience odour and traffic impacts from nearby industrial facilities; adding liquefaction and tanker movements would increase both risk and day-to-day burden on local residents.

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2. Grounds for Objection

I object to the MOD-6 chlorine liquefaction and packaging proposal unless major gaps in safety, transparency, and emergency planning are resolved. My concerns are:
1. Safety Case Transparency – The full Major Hazard Facility (MHF) safety case must be published, including worst-case chlorine release scenarios at 1 ppm (detectable), 10 ppm (IDLH), and 100+ ppm concentrations, with modelling specific to Jennings Street and local weather conditions.
2. Emergency Notification & PIRMP – Residents need clear, tested systems for immediate alerts (sirens, SMS, door-knocks). IXOM’s Pollution Incident Response Management Plan (PIRMP) should be released publicly and tested with the community.
3. Transport Risks – Liquefaction will increase tanker and cylinder transport. Routes, frequency, vehicle safety measures, and restrictions on residential road use must be disclosed and independently reviewed.
4. Cumulative Impacts – Matraville is a growing residential community with existing industrial emissions. This proposal must be assessed for cumulative risks and impacts alongside other facilities.
5. Legacy Contamination Context – The Botany site has a history of contamination and remediation. IXOM should explain how liquefaction interacts with past and ongoing remediation work.

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3. Specific Questions Needing Answer
• What is the maximum credible release volume, and what distances would be affected under different weather conditions?
• What safety instrumented systems (SIS) exist, what integrity (SIL) levels do they meet, and how are they tested?
• How quickly would Jennings Street residents be notified of a chlorine release, and by what method?
• How many tanker movements per week are planned, and which roads will be used?
• Will real-time chlorine monitoring data at the site boundary be made publicly available?

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4. Requested Conditions

If the project is to be considered, I request that at minimum the following conditions be imposed:
• Independent Peer Review: An external expert review of the safety case, dispersion modelling, and emergency systems must be completed and published.
• Community Notification: A dual system of sirens and SMS alerts must be installed and tested with Jennings Street residents prior to operations.
• Transport Restrictions: Chlorine tankers must be restricted from using Jennings Street and other residential roads, especially near schools and shops.
• Transparency: Real-time chlorine monitoring results at the site boundary must be publicly available online.
• Public Hearing: A public meeting/hearing must be held before determination, with IXOM, EPA, and SafeWork NSW required to answer community questions directly.

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5. Conclusion

Until the above information is provided and the conditions are guaranteed, I strongly object to the approval of MOD-6. This is a matter of community safety, environmental protection, and public trust.

I am a mother of 4 children. I reside at 15 Harold Street, Matraville.

I refer to the Application to NSW Government to upgrade the IXOM Chlorine Plant at 16-20 Beauchamp Road, Matraville, now on exhibition. The proposal is to commence operations to liquefy and package chlorine at 16-20 Beauchamp Road, Matraville.

This application has failed to inform residents of the risks the commencement of operations to liquify and package chlorine pose to the densely populated surrounding residents.

Chlorine is a highly toxic and reactive chemical. Its production and storage carry significant dangers including the potential for leaks, explosions, and long-term contamination.

The threat of accidental exposure to chlorine gas, even in small quantities, can result in severe respiratory damage, skin injuries, and lasting health complications.

In the event of a major incident, the consequences could be catastrophic for families living nearby.

The proposal to upgrade the IXOM Chlorine Plant at 16-20 Beauchamp Road, Matraville poses an unacceptable risk to public health, safety, and environmental wellbeing.

Given these risks, I am formally requesting the the NSW Government:

• Reject the application to commence operations to liquefy and package chlorine at 16-20 Beauchamp Road, Matraville.
• Engage independent experts to assess the long-term viability and safety of operating such a plant in close proximity to homes.
• Commission independent experts to conduct a full safety and environmental review.
• Provide transparent communication to residents regarding current safety protocols, emergency response plans, and monitoring systems.
• Explore relocation or repurposing of the facility to eliminate the threat to our community.

The proposed operation of this chlorine plant so close to residential homes is not only dangerous it is unjustifiable.

Our community deserves to live free from the fear of chemical exposure and industrial disaster.

The application to upgrade the IXOM Chlorine Plant at 16-20 Beauchamp Road, Matraville has been dressed up to hoodwink local residents. I attach a copy of the letter circulated to residents regarding the application designed to placate and deceive residents into failing to identify the clear danger of the proposed application.

I have and will continue to approach other residents to make them aware of the danger this proposal poses to our health and safety, and to voice their concerns and opposition to the application.

Thank you for your time and assistance in this matter.

I am a resident of Bayside LGA and I strongly object to the proposed modification of D/A 35/98 for the chlorine plant in the Botany Industrial Park.

• The original approval in 1998 did not properly assess transport risks, so the consent was flawed.

• Chlorine is highly toxic and transported daily along Denison Street, Wentworth Avenue and Bunnerong Road, putting local residents, shoppers and road users at risk.

• A 2019 risk assessment showed unacceptable fatality risks, but further studies recommended by independent experts were never done.

• Unlike similar chlorine plants in Victoria, there are no buffer zones or safeguards to protect residents here.

• In the public interest, the plant should not be expanded or modified — it should be relocated away from residential areas.

Please refuse this modification.

Sincerely Andrea Jackson

Ref attached.

I am a resident of hillsdale and I strongly object to the proposed modification of D/A 35/98 for the chlorine plant in the Botany Industrial Park.


The original approval in 1998 did not properly assess transport risks, so the consent was flawed.


Chlorine is highly toxic and transported daily along Denison Street, Wentworth Avenue and Bunnerong Road, putting local residents, shoppers and road users at risk.


A 2019 risk assessment showed unacceptable fatality risks, but further studies recommended by independent experts were never done.


Unlike similar chlorine plants in Victoria, there are no buffer zones or safeguards to protect residents here.


In the public interest, the plant should not be expanded or modified — it should be relocated away from residential areas.


I urge you to refuse this modification and act to protect the safety of our community.

Yours sincerely,

Local resident in grace Campbell Crescent hillsdale

I am a resident of Hillsdale and I strongly object to the proposed modification of D/A 35/98 for the chlorine plant in the Botany Industrial Park.

The original approval in 1998 did not properly assess transport risks, so the consent was flawed.

Chlorine is highly toxic and transported daily along Denison Street, Wentworth Avenue and Bunnerong Road, putting local residents, shoppers and road users at risk.

A 2019 risk assessment showed unacceptable fatality risks, but further studies recommended by independent experts were never done.

Unlike similar chlorine plants in Victoria, there are no buffer zones or safeguards to protect residents here.

In the public interest, the plant should not be expanded or modified — it should be relocated away from residential areas.

I urge you to refuse this modification and act to protect the safety of our community.
Yours sincerely,
Yong

Please refer to attachments.

Please see supporting documentation from General Manager Operations - Brendan Windmeyer at TasWater (Tasmanian Water and Sewerage Corporation Pty Ltd.

I, Teagan Booth are making this submission on his behalf.

I am a resident of Bayside Council area and I strongly object to the proposed modification of D/A 35/98 for the chlorine plant in the Botany Industrial Park. The original approval in 1998 did not properly assess transport risks, so the consent was flawed.
Chlorine is highly toxic and transported daily along Denison Street, Wentworth Avenue and Bunnerong Road, putting local residents, shoppers and road users at risk. A 2019 risk assessment showed unacceptable fatality risks, but further studies recommended by independent experts were never done. Unlike similar chlorine plants in Victoria, there are no buffer zones or safeguards to protect residents here. In the public interest, the plant should not be expanded or modified — it should be relocated away from residential areas. I urge you to refuse this modification and act to protect the safety of our community.

Yours sincerely,
Aydar Shamsutdinov

I am a resident of Hillsdale and I strongly object to the proposed modification of D/A 35/98 for the chlorine plant in the Botany Industrial Park.
The original approval in 1998 did not properly assess transport risks, so the consent was flawed.
Chlorine is highly toxic and transported daily along Denison Street, Wentworth Avenue and Bunnerong Road, putting local residents, shoppers and road users at risk.
A 2019 risk assessment showed unacceptable fatality risks, but further studies recommended by independent experts were never done.
Unlike similar chlorine plants in Victoria, there are no buffer zones or safeguards to protect residents here.
In the public interest, the plant should not be expanded or modified — it should be relocated away from residential areas.
I urge you to refuse this modification and act to protect the safety of our community.

Reagards,
Mohammad B. Ghasemian
22-24 Rhodes St Hillsdale

See attached submission from Sydney Water

Please find a letter of support attached.

Australian Water Authorities depend on the production and distribution of liquefied chlorine gas to ensure the safe disinfection of potable water for residents across the country.
Currently, there is only one domestic producer of liquefied chlorine gas (located in Laverton, Victoria), resulting in limited supply resilience for this essential resource—particularly for Melbourne Water.
In light of this, Melbourne Water supports initiatives that diversify and strengthen the national production capacity of liquefied chlorine gas.
The proposed modification and operation of the ChlorAlkali Plant in Sydney as an additional manufacturing source directly contributes to this objective.
It enhances supply security and mitigates sovereign risk by reducing reliance on a single production site, thereby safeguarding against potential domestic supply disruptions.

I am a resident of Hillsdale and I strongly object to the proposed modification of D/A 35/98 for the chlorine plant in the Botany Industrial Park.
* The original approval in 1998 did not properly assess transport risks, so the consent was flawed.
* Chlorine is highly toxic and transported daily along Denison Street (my street), Wentworth Ave and Bunnerong Road, putting local residents, shoppers and road users at risk.
* A 2019 risk assessment showed unacceptable fatality risks, but further studies recommended by independent experts were never done.
* Unlike similar chlorine plants in Victoria, there are no buffer zones or safeguards to protect residents here.
* In the interests of public safety, the plant should not be expanded or modified - it should be relocated away from residential areas.
My husband and I have lived in the same house on Denison Street for over 40 years, raising our family of 3 sons, and now helping with 2 granddaughters. I clearly remember the chlorine alarms going off, myself and toddler son being affected by chlorine leaks on more than one occasion. We have no inclination to move at this stage of our lives, and don’t see why we should be forced out.
I urge you to refuse this modification and act to protect the safety of our community.
Yours sincerely
Lynne Salakas
34 Denison Street
Hillsdale

RE: Objection to D/A 35/98 – Chlorine Plant Modification

To whom it concerns,

I am a resident of Botany and I strongly object to the proposed modification of D/A 35/98 for the chlorine plant in the Botany Industrial Park.

The original approval in 1998 did not properly assess transport risks, so the consent was flawed.

Chlorine is highly toxic and transported daily along Denison Street, Wentworth Avenue and Bunnerong Road, putting local residents, shoppers and road users at risk.

A 2019 risk assessment showed unacceptable fatality risks, but further studies recommended by independent experts were never done.

Unlike similar chlorine plants in Victoria, there are no buffer zones or safeguards to protect residents here.

In the public interest, the plant should not be expanded or modified — it should be relocated away from residential areas.

I urge you to refuse this modification and act to protect the safety of our community.
Yours sincerely,
Resident
Botany Road, Botany

Please refer to attached submission letter.