December 3, 2019

Randall R. Lay
Chief Financial Officer
Williams Industrial Services Group Inc.
100 Crescent Centre Parkway, Suite 1240
Tucker, Georgia 30084

       Re: Williams Industrial Services Group Inc.
           Registration Statement on Form S-1
           Filed November 14, 2019
           File No. 333-234702

Dear Mr. Lay:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-1

Certain Material U.S. Federal Income Tax Consequences, page 45

1.     We note the reference to "material U.S. federal income tax consequences"
on page 45 and
       the statements on page 12 and elsewhere that an investor should not
recognize income or
       loss in connection with the receipt or exercise of Rights for federal
tax purposes. Please
       file a tax opinion on the material U.S. federal income tax consequences
of the transaction,
       as required by Item 601(b)(8) of Regulation S-K. Alternatively, please
tell us how you
       determined a tax opinion is not required. For guidance, refer to Section
III of Staff Legal
       Bulletin No. 19.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
 Randall R. Lay
Williams Industrial Services Group Inc.
December 3, 2019
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Ruairi Regan at 202-551-3269 or David Link at
202-551-3356 with
any questions.



                                                           Sincerely,
FirstName LastNameRandall R. Lay
                                                           Division of
Corporation Finance
Comapany NameWilliams Industrial Services Group Inc.
                                                           Office of Real
Estate & Construction
December 3, 2019 Page 2
cc:       Stuart Welburn, Esq.
FirstName LastName