SecProbe.io

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July 25, 2005

By facsimile to (617) 523-6215 and U.S. Mail

Mr. Alan S. McKim
Chairman, President, and Chief Executive Officer
Clean Harbors, Inc.
1501 Washington Street
Braintree, MA 02184-7535

Re:	Clean Harbors, Inc. and Registrant Guarantors
	Registration Statement on Form S-4
	Filed June 28, 2005
File No. 333-126193

Clean Harbors, Inc.
Annual Report on Form 10-K for the fiscal year ended December 31,
2004 and Subsequent Exchange Act Reports
File No. 0-16379

Dear Mr. McKim:

	We reviewed the filings and have the comments below.

	Where indicated, we think that you should revise the
documents
in response to the comments.  If you disagree, we will consider
your
explanation why a comment is inapplicable or a revision is
unnecessary.  Be as detailed as necessary in your explanation.  To
understand better your disclosure, we may ask you in some comments
to
provide us supplemental information.  We may raise additional
comments after reviewing this information.

	Our review`s purpose is to assist you in your compliance with
applicable disclosure requirements and to enhance the overall
disclosure in your documents.  We look forward to working with you
to
achieve these objectives.  We welcome any questions that you may
have
about comments or any other aspect of our review.  You may call us
at
the telephone numbers listed at the end of this letter.

1. Please tell us your intentions for the preliminary proxy
statement
that was last revised on January 16, 2003.  If you intend to
withdraw
the proxy statement, file separate correspondence on the EDGAR
system
to that effect.

2. If applicable, comments on the S-4 are comments on the 10-K and
subsequent Exchange Act reports and vice versa.  As applicable,
address comments below in future filings under the Exchange Act.

3. We note that you are registering the new notes in reliance on
our
position enunciated in Exxon Capital Holdings Corporation
(available
April 13, 1989), Morgan Stanley & Co. Incorporated (available June
5,
1991), and Shearman and Sterling (available July 2, 1993).
Provide a
supplemental letter on the letterhead of Clean Harbors, Inc. or
Clean
Harbors signed by an officer before the S-4`s effectiveness:

* stating that you are registering the exchange offer in reliance
on
our position in those letters, and

* including the statements and representations substantially in
the
form presented in the Morgan Stanley & Co. Incorporated and
Shearman
and Sterling letters.

4. We note that you intend to file by amendment the legality
opinion.
Allow us sufficient time to review the opinion before requesting
acceleration of the registration statement`s effectiveness.

5. On page 1 and throughout the document where you discuss EBITDA,
discuss also your net income (loss) as calculated and presented
according to GAAP.  See Item 10(e)(1)(i)(A) of Regulation S-K.

6. We note that you refer to third parties throughout the filing,
including the financial statements` notes.  For example, refer to
"independent appraisal firm" on page 35, "Tillinghast Towers
Perrin"
on page 74, and "legal counsel" on pages 104 and 109.  If you
refer
to third parties, you need to identify them and obtain their
consent.
Otherwise, you should delete all references to third parties.  See
Rule 436 of Regulation C under the Securities Act.

7. Explain the meaning of any abbreviation or acronym when
introduced
in the registration statement.  For example, refer to "PRPs" in
the
first full paragraph on page 60.

Prospectus` Outside Front Cover Page

8. Identify the guarantees as securities that you are offering
with
the notes by way of this prospectus.

9. Refer to the fourth bullet point.  Confirm for us that the
offer
will be open for a full 20 business days.  At present, it appears
that the offer could be open for less than the required 20
business
days because the offer expires at 5:00 P.M. instead on midnight on
what may ultimately be the twentieth business day after it begins.
See Rule 14d-1(g)(3) under the Exchange Act and Q&A 8 in Release
No.
34-16623, March 5, 1980.  We note the disclosure in the second
bullet
point on page 117.

10. Delete the word "generally" in the fifth bullet point because
the
word "generally" may imply that investors cannot rely on the
disclosure.  Also delete the word "generally" under "Tax
Consequences" on page 9 and under "Sale or Exchange of Notes" on
page
176 and the language "for general information" in the bold type
paragraph on page 178 for the same reason.

11. Remove any information not required by Item 501 of Regulation
S-K
and not key to an investment decision.

12. Except for footnotes, the typeface should be uniform
throughout
the document.  Currently, the type on the prospectus` outside
front
cover page appears too small.  Please revise.

13. Move all information except that required by Item 2 of Form S-
4
after "Table of Contents" on pages ii-iv so that it follows the
summary and risk factors sections.  See Item 502 and 503(c) of
Regulation S-K.

Available Information, page ii

14. It appears that you are providing disclosure under Item 10 of
Form S-4.  If so, please revise to include all documents required
to
be incorporated by Item 11 of Form S-4.

Industry and Market Data, page iv

15. Amend this paragraph`s language to remove the implication that
you are disclaiming responsibility for information that you have
chosen to include in the prospectus.

Prospectus Summary, page 1

16. The summary is much too detailed and includes information
about
Clean Harbors and its business that is repeated essentially word
for
word on pages 75-80.  We note particularly the subsections on
Clean
Harbors` competitive strengths and business strategy.  The
emphasis
on those features or aspects without a discussion of corresponding
risks also leaves the summary somewhat unbalanced.  Revise so that
the summary highlights in a brief overview the key aspects or
features of Clean Harbors and its business, eliminating the two
subsections mentioned.  See Item 503(a) of Regulation S-K.

17. Ensure that the information that you retain in the summary is
balanced.  For example, you disclose revenue and EBITDA for the 12
month period ended March 31, 2005, but you do not disclose that
earnings were insufficient to cover fixed charges during the years
ended December 31, 2003 and 2002.  Further, disclosure in footnote
(8) on page 15 states that "Previous definitions of EBITDA were
based
on financial arrangements then in place and varied somewhat from
the
current definition of EBITDA."

18. Identify the notes` initial purchasers under "Background" on
page
6.

19. Provide the book value of the collateral as of the date of the
most recent balance sheet included in the prospectus.  Also
disclose
the maximum amount of first-lien obligations that you are
permitted
to incur.

20. We assume that the reference to "this offering circular" under
"Optional Redemption" on page 11 is inadvertent.  Please revise.

21. Revise "Change of Control" on page 11 to disclose that if
there
is a change of control, Clean Harbors may have insufficient
financial
resources or may be unable to arrange financing to repurchase the
notes.

Risk Factors, page 18

22. Many risk factors` captions or headings state merely a fact or
describe an event that may occur in the future or are too vague to
describe adequately the risk that follows.  For example, refer to
the
first, second, fourth, fifth, seventh, eighth, ninth, tenth,
eleventh, twelfth, thirteenth, fourteenth, fifteenth, sixteenth,
seventeenth, eighteenth, nineteenth, twentieth, twenty-first, and
twenty-second risk factors.  State succinctly the risk that
follows
from the fact or uncertainty.

23. Avoid generic conclusions in the risk factors` captions or
headings and in the risk factors` discussions such as Clean
Harbors`
results of operations, business, and financial condition would or
could be materially and adversely affected or would or could be
harmed.  For example, refer to the third and nineteenth risk
factors.
Rather, explain specifically what the risk`s consequences or
effects
are for Clean Harbors and its investors.

24. Some risk factors include language like "we cannot assure, "we
can not assure," "we cannot guarantee," "there can be no
assurance,"
and "we cannot provide assurance."  For example, refer to the
second,
third, fifth, sixth, ninth, tenth, fourteenth, and nineteenth risk
factors.  Since the risk is the situation described and not your
inability to assure or guarantee, revise.

25. In the fifth risk factor, quantify your debt service
obligations.

Selected Historical Consolidated Financial Data, page 28

26. Since you have adjusted EBITDA for charges other than
interest,
taxes, depreciation, and amortization expenses you should revise
your
title to reflect that fact.  Refer to Question 14 in the June 13,
2003 FAQ on Non-GAAP Financial Measures.

27. Since the EBITDA amounts presented on page 16 for the years
ended
December 31, 2002 and December 31, 2003 do not agree to the
amounts
presented in note 23 to the financial statements, it appears that
you
are disclosing two different amounts of EBITDA.  Explain why you
have
two different amounts and why you believe that both are useful to
investors.  Also revise the titles so that you are not using the
same
title for both amounts.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations
Critical Accounting Policies and Estimates, page 36

28. Expand your discussion of critical accounting policies to
address
these items:

* Indicate whether you have discussed your critical accounting
estimates with your audit committee.

* Provide a quantitative discussion of changes in your overall
financial performance if you were to assume that the accounting
estimates were changed by using reasonably possible near term
changes
in the most material assumptions underlying the accounting
estimates
or by using the reasonably possible range of the accounting
estimates.  For example, we would expect to see a detailed
discussion
of the significant assumptions used in arriving at your closure
and
post-closure obligations.  This discussion should include the
inflation and discount rates used and the impact on your financial
results if you assumed changes in these assumptions.

* Provide a quantitative and qualitative discussion of any
material
changes made to the accounting estimates in the past three years,
the
reasons for the changes, and the effect on your overall financial
performance.

		See Release Nos. 33-8040, 33-8098, and 33-8350.

Results of Operations, page 39

29. Enhance your MD&A disclosures by including these items:

* Quantify the impact of each factor when multiple factors
contribute
to material fluctuations in a line item.  For material
fluctuations
in net sales, discuss the extent to which the fluctuation is due
to
pricing, volumes sold, or the introduction of new products.

* Discuss the nature of the items included in corporate revenues
and
cost of revenues.  Also discuss and quantify the reasons for the
fluctuations in corporate items.

      See Item 303(a) of Regulation S-K.

Environmental Liabilities, page 50

30. You state that landfill assets are amortized and closure and
post-closure costs are accrued as airspace is consumed.  Disclose
the
rates that you used for the amortization of landfill costs and the
accrual of closure and post-closure costs during each period
presented.  If applicable, discuss the reasons for material
fluctuations.

31. Provide a rollforward of landfill assets for each period
presented.

32. Since the 7.8 million cubic yards of unpermitted airspace
included in probable airspace did not meet your established
criteria
for determining if unpermitted airspace should be included in
probable airspace, disclose the impact of including this airspace
on
your income from operations for each period presented.  Also
disclose
the reasons for not having submitted the permit application and
when
you intend to submit the permit application.

33. Since the changes in estimates resulted in a reduction of
closure
and post-closure liabilities of approximately 12% during the year
ended December 31, 2004 and 19% during the year ended December 31,
2003, disclose the facts and circumstances that led to these
changes
in your estimates.  Also disclose how the "other changes in
estimates" are reflected in your financial statements.

Changes in Internal Control over Financial Reporting, page 73

34. You state that "except as otherwise discussed elsewhere in
this
prospectus, there have not been any changes in the Company`s
internal
control over financial reporting."  Remove this wording, and
disclose
in this section all changes in your internal control over
financial
reporting that occurred during your last fiscal quarter that has
materially affected or is reasonably likely to materially affect
your
internal control over financial reporting.  See Item 308(c) of
Regulation S-K.

Business, page 76

35. State the duration of Clean Harbors` three patents under
"Intellectual Property" on page 90.  See Item 101(c)(1)(iv) of
Regulation S-K.

36. State in the first full paragraph on page 106 the amount of
reserves that Clean Harbors has established to cover its estimated
legal costs for the lawsuit against Clean Harbors Plaquemine, LLC.
Specify the known or estimated amount of civil penalties that the
plaintiffs are seeking in the lawsuit.

37. If true, indicate in the second full paragraph on page 109
that
the Norfolk Superior Court and the Suffolk Superior Court are
located
in the state of Massachusetts.

The Exchange Offer, page 116

38. Revise the language "as soon as practicable" so that it reads
"promptly" in the first and eighth paragraphs under "Terms of the
Exchange" on pages 118-119.  Similarly, revise the third paragraph
under "Expiration Date; Extensions; Amendments" on page 120, the
ninth paragraph under "Procedures for Tendering" on page 122, the
third paragraph under "Withdrawal of Tenders" on page 125, and the
second paragraph on page 10 of exhibit 99.1.  See Rule 14e-1(c)
under
the Exchange Act.

Expiration Date; Extensions; Amendments, page 120

39. You state in the first bullet point that you reserve the right
to
delay accepting any old notes.  Clarify in what circumstances you
will delay acceptance.  For example, if you are referring to the
right to delay acceptance only due to an extension of the exchange
offer, so state.  Confirm for us that any delay will be consistent
with Rule 14e-1(c) under the Exchange Act.

40. You state in the second bullet point and in the first full
paragraph on page 2 of exhibit 99.1 that you reserve the right to
extend the exchange offer.  Advise us how oral notice of any
extension is reasonably calculated to reach registered holders of
the
outstanding notes or otherwise satisfies the requirements of Rule
14e-1(d) under the Exchange Act.

41. Clarify that you will make a public announcement of any
extension
of the exchange offer no later than 9:00 A.M. Eastern time on the
next business day after the scheduled expiration date as required
by
Rule 14e-d(1) under the Exchange Act.  Confirm that you will
disclose
the approximate number of notes tendered to date with your public
announcement of an extension as required by Rule 14e-1(d) under
the
Exchange Act.

42. You state in the third bullet point that you reserve the right
to
terminate the exchange offer if in your "sole judgment" a
condition
is not satisfied.  We do not object to the imposition of
conditions
in a tender offer, provided that they are not within the direct or
indirect control of the offeror and are specific and capable of
objective verification when satisfied.  Thus, we suggest that you
revise the bullet point to clarify that Clean Harbor will make its
determination in its "reasonable discretion" or "reasonable
judgment."  Similarly, revise the last bullet point under
"Conditio