MOD 6 Chlorine Liquefaction Plant

Obtaining planning approval for the Botany plant to resume chlorine liquefaction and packaging will provide the water industry with an option for increased supply security of liquefied chlorine gas. It will also ensure supply chain risk is minimised and business continuity is maintained across the water sector

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.
Yours sincerely,
Yong

I have some concerns with the proposal for the reinstatement of chlorine extraction at the IXOM Botany Site. I have sent these concerns to the IXOM contact directly and was told someone from the project team will get back to me shortly. I understand that they are very busy and have not had time to get back to me yet.

I am also aware that the plant preceded suburban development. However suburbia has now encroached on the site to the extent that awareness of the physical dangers is important.

Below I have copied my email to the IXOM team. Here in summary are my concerns:

There was a reason for closing the chlorine liquefaction plant in the past. How have these concerns been addressed?
Their report was not clear in what form chlorine was to be transported out of the plant. Is it in the form of sodium hypochlorite (NaOCl), or would liquefied chlorine (pure dried Cl2) ever be transported? Apparently most chlorine accidents happen when pressure vessels (on road or rail transport) are punctured. When this happens, the chlorine evaporates, but being heavier than air, stays close to the ground. This would result in deaths, severe respiratory casualties and metal corrosion (allowed level for humans is 1 ppm over 8 hours).
I am concerned about the emergency chlorine vent and its use during production accidents. Would chlorine gas ever be vented, and how would this be managed?

Since I don't have answers yet to these concerns, I would currently have to oppose this project. I am in discussion with my neighbours who also have concerns.

Thanks for your consideration of these concerns,

Robert.
11A Harold St Matraville.



COPY OF EMAIL TO IXOM:

Concerning the proposal to modify the plant, I have a few questions that I couldn't easily find answers to. This is partly because I am not sure whether the term 'chlorine' in the plant upgrade documentation refers to liquefied Cl2 or sodium hypochlorite (NaOCl):

Q1. In what form is liquefied chlorine to be stored (as pure liquefied Cl2 or as NaOCl or both).
Q2. What does the emergency chlorine vent release? Can it release chlorine gas to the environment (I'm a nearby resident)? Has this ever happened before? What safety measures protect us from gas release?
Q3. Is liquefied chlorine gas to be sent by rail, or is NaOCl only transported?
Q4. Is liquefied chlorine gas to be sent by tanker (road transport), or is NaOCl only transported?
Q5. Historically incidents of gas release happen when pressurized vessels are ruptured accidentally. What prevents this happening at the plant, and what mitigates this if it does happen?
Q6. In the compressed chlorine cooling stage, what is used as the cooling liquid? Do I need to be concerned about this as well? (for example, is water (brine), ammonia or liq nitrogen used?)

Dear Sir/Madam

I am writing to formally express my concern and objection to the proposed establishment of a Chlorine Liquefaction Plant at 16-20 Beauchamp Road, Matraville. As a resident of the nearby Randwick Council area, which is only 300 meters from the proposed site, I feel compelled to voice my concerns about the significant risks this plant poses to the health and safety of surrounding communities.

First and foremost, I am alarmed by the potential hazards associated with the handling and liquefaction of chlorine at this facility. Chlorine, as you are aware, is a toxic and hazardous substance, and any leakage or accidental release poses serious risks to the environment and public health. The proximity of this plant to residential areas, schools, and other public spaces is deeply concerning. A plant of this nature has the potential to cause widespread harm to the local community, and I believe it is imperative that the government consider these dangers before proceeding with the approval of this proposal.

Additionally, it is troubling to note that residents of the Randwick Council area, including myself, were not properly informed of this development. The proposed plant lies in the Bayside Council ward, and despite our close proximity to the site, no outreach or consultation efforts were made to engage with residents in Randwick. This lack of communication and transparency is unacceptable, particularly when it concerns a facility with such potentially catastrophic implications. It is essential that all affected communities are adequately informed and given the opportunity to voice their concerns, especially when their safety and well-being are at stake.

Given these serious concerns, I respectfully urge the NSW Government to reject the proposal for the Chlorine Liquefaction Plant at 16-20 Beauchamp Road, Matraville. The risks to public safety, the lack of appropriate community consultation, and the potential for environmental harm make this project an untenable choice for the local area. I ask that the government prioritize the health, safety, and interests of residents over the development of such a hazardous facility.

Thank you for your attention to this matter. I trust that you will take the necessary steps to reconsider this proposal and ensure the protection of the local community.

Yours sincerely,
Thomas Buxton

I am a resident of Banksmeadow 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,
A concerned resident

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

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

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

Submission on D/A 35/98 – Modification 8: Ixom Chlorine Liquefaction Plant

From: Maria Poulos, No Overdevelopment Pagewood and Eastgardens (NOPE) residents group
Date: 16 September 2025

INTRODUCTION

This submission is an objection to the proposed modification of development consent D/A 35/98 for the Ixom chlorine liquefaction plant in the Botany Industrial Park.
This facility poses unacceptable risks to the surrounding community because of its production, storage and transport of toxic chlorine gas. The original approval granted in 1998 was flawed and did not properly assess transport risks, leaving residents, workers and shoppers exposed for more than two decades.
The modification now sought should not be approved. In the public interest, the NSW Government should instead consider options to relocate the chlorine facility away from residential areas, schools and major shopping centres.

KEY CONCERNS
1. Original Approval was Unlawful and Incomplete
• In 1998, Orica (the former operator) received consent for a replacement chlorine plant.
• Required safety assessments — including a full Preliminary Hazard Analysis and transport risk study — were not carried out in line with SEPP 33 and HIPAP No. 6.
• This means the risks associated with transporting chlorine through Denison Street, Wentworth Avenue and Bunnerong Road were never properly considered.

2. Evidence of Unacceptable Risk
• Independent risk assessments (e.g. the 2015 Scott Lister QRA and 2019 Westfield Eastgardens QRA) have since shown that residents and shoppers are exposed to unacceptable fatality risks from chlorine transport accidents.
• Expert reviewers (Arriscar) recommended further studies, particularly around building wake effects and taller developments, but these have never been undertaken.
• Safety measures proposed for shopping centres (sealed walls, HVAC pressurisation) do nothing to protect residents living along Wentworth Avenue and Bunnerong Road, who remain highly vulnerable.

3. Inconsistent with Best Practice
• Chlorine facilities in other states, such as Laverton, Victoria, operate under strict buffer zones to keep residents at a safe distance.
• No such protections exist in Botany, despite the much higher population density around the plant.

4. Public Interest and Urban Planning
• Thousands of people live, shop, study and work daily within the chlorine transport corridor.
• The Eastgardens redevelopment and new high-rise towers will only increase the number of people exposed.
• Continuing to approve modifications under a flawed and incomplete 1998 consent is contrary to the public interest.

OUR POSITION
• The 1998 approval for the Orica chlorine plant was unlawful because it failed to consider transport risks.
• The current modification request (D/A 35/98 – Mod 8) should be refused.
• In the public interest, Council should move to relocate the chlorine plant away from residential and retail areas to reduce unacceptable risks.

CONCLUSION
Botany, Pagewood and Eastgardens residents should not be exposed to toxic chlorine risks simply because of outdated and incomplete approvals made more than 25 years ago.
The Government has a responsibility to act in the interests of community safety. Refusing the proposed modification and working towards relocation of the plant is the only safe and sensible course of action.

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.

Ref attached.

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.

⸻

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.

⸻

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?

⸻

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.

⸻

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.

See attached