September 16, 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
	Pre-effective Amendment 1 to Registration Statement on Form
S-4
	Filed August 31, 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.

1. If applicable, comments on the S-4 are comments on the 10-K and
subsequent Exchange Act reports and vice versa.

Prospectus` Outside Front Cover Page

2. Refer to prior comment 11.  Remove the paragraph that follows
the
cross reference to the risk factors section.  We note the
disclosure
on page 121.



Table of Contents, page i

3. Refer to prior comment 13.  As noted previously, you must
include
information required by Item 2 of Form S-4 on the inside front
cover
page.  Further, move the paragraph before "Table of Contents" so
that
it follows the summary and risk factors sections.  See Item 502
and
503(c) of Regulation S-K.

Prospectus Summary, page 1

4. Refer to prior comment 16.  The summary remains much too
detailed
and continues to include information about Clean Harbors and its
business that is repeated essentially word for word on pages 77,
78-
79, and 82.  Please revise.

Risk Factors, page 15

5. Refer to prior comment 22.  Many risk factors` captions or
headings continue to 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 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.

Disclosure Regarding Forward-Looking Statements, page 24

6. Since the offering is a tender offer, Clean Harbors is
ineligible
to rely on the safe harbor for forward-looking statements under
section 27(A)(b)(2)(C) of the Securities Act.  Thus, Clean Harbors
should delete the phrase "as defined by federal securities laws"
in
this section`s first sentence.  Alternatively, Clean Harbors
should
explain that it is ineligible to rely on the safe harbor.

Industry and Market Data, page 25

7. Refer to prior comment 15.  Delete the phrase "for certain of
such
information" in this section`s last sentence.

Environmental Liabilities, page 51

8. We have reviewed your response to comment 32.  Please disclose
the
reasons for not having submitted the permit application for the
7.8
million cubic yards of unpermitted airspace included in probable
airspace and when you intend to submit the permit application.

9. We have reviewed your response to comment 33.  Please provide
us
with the following additional information regarding the $11.6
million
reduction in landfill assets during the year ended December 31,
2003.
Specifically, address the following:

* Please tell us when the initial landfill asset was recorded, the
amount of the initial asset recorded, how you recorded this
amount,
and how you determined it was appropriate at this time to record
this
amount; and

* Please tell us the specific facts and circumstances that led you
to
believe that additional airspace was available, including the
specific business opportunities that made possible the expansion
and
further utilization of the assets acquired from CSD that its
management previously believed to be exhausted.

10. Please provide us with the following additional information
regarding the $7.5 million change in estimate recorded during the
six
months ended June 30, 2005.  Specifically, please address the
following:

* Please tell the specific facts and circumstances that occurred
during the six months ended June 30, 2005 that led you to
determine
it was appropriate record the $2.1 million reduction for financial
assurance.  Tell us how you arrived at the appropriate amount to
record, including the specific assumptions used;

* Please provide us with a breakdown of the $3.5 million net
benefit
recorded.  Tell us the amount recorded for each of the three
factors
you listed.  For each of these amounts tell us how you arrived at
the
appropriate amount to record, including the specific assumptions
used.

Note 4.  Significant Accounting Policies

(j)  Property, Plant and Equipment, page F-16

11. We have reviewed your response to comment 56 and the
additional
disclosures provided.  Given that the changes in estimates in
landfill lives and changes in estimates in useful lives of certain
assets resulted in an approximately 40% increase in pre-tax income
before cumulative effect of change in accounting principle for the
year ended December 31, 2004, please provide us with a detailed
explanation of these changes.  Your explanation should discuss the
components of the $3.5 million.  For each component or change in
estimated life, please tell us the original useful life used, the
new
useful life, and the specific facts and circumstances that led you
to
determine it was appropriate to change the useful life.

Expiration Date; Extensions; Amendments, page 123

12. Refer to prior comment 39.  Based on your response that Clean
Harbors` right to delay accepting any old notes would be due only
to
an extension of the exchange offer, revise the first and second
bullet points to make that clear.

Conditions to the Exchange Offer, page 123

13. Refer to prior comment 44.  Delete the phrase "or receipt of
any
required governmental approval" in this section`s first
paragraph`s
first sentence.  You make that disclosure in the third bullet
point.

14. Refer to prior comment 45.  The revised disclosure is unclear
that all conditions to the exchange offer other than those
dependent
upon receipt of necessary governmental approvals must be satisfied
or
waived before the exchange offer`s expiration.  Revise the first
full
paragraph on page 124, the last paragraph on page 125, and the
first
full paragraph on page 2 of exhibit 99.1 to make it clear that all
conditions to the exchange offer other than those dependent upon
receipt of necessary governmental approvals must be satisfied or
waived before the exchange offer`s expiration.

Description of the New Notes, page 130

15. Refer to prior comment 47.  The revised disclosure is unclear
that investors have rights under the United States federal
securities
laws about the notes` description in the prospectus.  Please
revise.

Exhibit 5.1

16. Delete the statement under (i) in the second paragraph on page
2.

FORM 10-Q FOR THE PERIOD ENDED JUNE 30, 2005

General

17. Please address the comments above in your interim filings as
well.

Closing

	File an amendment to the S-4 in response to the comments.  To
expedite our review, Clean Harbors may wish to provide us three
marked courtesy copies of the amendment.  Include with the filing
any
supplemental information requested and a cover letter tagged as
correspondence that keys the responses to the comments.  If Clean
Harbors thinks that compliance with any of the comments is
inappropriate, provide the basis in the letter.  We may have
additional comments after review of the amendment, the responses
to
the comments, and any supplemental information.

	We urge all persons responsible for the accuracy and adequacy
of
the disclosure in the registration statement reviewed by us to
ensure
that they have provided all information investors require for an
informed decision.  Since Clean Harbors and its management are in
possession of all facts relating to the disclosure in the
registration statement, they are responsible for the adequacy and
accuracy of the disclosures that they have made.

      If Clean Harbors requests acceleration of the registration
statement`s effectiveness, Clean Harbors should furnish a letter
at
the time of the request, acknowledging that:

* Should the Commission or the staff acting by delegated authority
declare the registration statement effective, it does not
foreclose
the Commission from taking any action on the filing.

* The action of the Commission or the staff acting by delegated
authority in declaring the registration statement effective does
not
relieve Clean Harbors from its full responsibility for the
adequacy
and accuracy of the disclosure in the registration statement.

* Clean Harbors may not assert our comments and the declaration of
the registration statement`s effectiveness as a defense in any
proceedings initiated by the Commission or any person under the
United States` federal securities laws.

	The Commission`s Division of Enforcement has access to all
information that Clean Harbors provides us in our review of the
registration statement or in response to our comments on the
registration statement.

	We will consider a written request for acceleration of the
registration statement`s effectiveness under Rule 461 of
Regulation C
under the Securities Act as confirmation that those requesting
acceleration are aware of their responsibilities under the
Securities
Act and the Exchange Act as they relate to the proposed public
offering of the securities specified in the registration
statement.
We will act on the request and by delegated authority grant
acceleration of the registration statement`s effectiveness.

	You may direct questions on accounting comments to Gustavo A.
Rodriguez, Staff Accountant, at (202) 551-3752 or Nudrat S. Salik,
Senior Staff Accountant, at (202) 551-3692.  You may direct
questions
on other comments and disclosure issues to Edward M. Kelly, Senior
Counsel, at (202) 551-3728 or Christopher B. Edwards, Special
Counsel, at (202) 551-3742.

Very truly yours,





Pamela A. Long

Assistant Director

cc:	C. Michael Malm, Esq.
	Davis, Malm & D`Agostine, P.C.
	1 Boston Place
	Boston, MA 02108



Mr. Alan S. McKim
September 16, 2005
Page 1








UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE