September 13, 2018

Joel Mostrom
Chief Financial Officer
Babcock & Wilcox Enterprises, Inc.
13024 Ballantyne Corporate Place, Suite 700
Charlotte, North Carolina 28277

       Re: Babcock & Wilcox Enterprises, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2017
           Filed March 1, 2018
           File No. 001-36876

Dear Mr. Mostrom:

       We have reviewed your filing and have the following 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2017

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Critical Accounting Policies and Estimates
Goodwill and long-lived asset impairment, page 53

1.    We note that you fully impaired SPIG's goodwill during the second quarter
of fiscal year
      2018 due to issues with specific contracts, changes to SPIG's market
strategy, and lower
      bookings than previously forecasted. We also note that SPIG has incurred
increased
      losses for the six months ended June 30, 2018. As such, please provide
disclosures for the
      material uncertainty associated with SPIG's identifiable intangible
assets, including the
      specific factors that could lead to an impairment charge, or provide us
with the specific
      facts and circumstances that indicate there is not a material
uncertainty. Please refer to
 Joel Mostrom
Babcock & Wilcox Enterprises, Inc.
September 13, 2018
Page 2
         Item 303(a)(3) of Regulation S-K, SAB Topic 5:P.4, and Sections 216,
501.02,
         501.12.b.3, and 501.14 of the Financial Reporting Codification for
guidance regarding
         forewarning disclosures.
Note 10   Provision for Income Taxes, page 85

2.       We note that you have net deferred tax assets of $93.3 million as of
December 31, 2017,
         and that you have been in a three-year cumulative loss position since
December 31, 2016.
          Please provide us with your comprehensive analysis of the specific
positive and negative
         evidence management evaluated in arriving at the conclusion that a
full valuation
         allowance is not needed as of December 31, 2017. Your analysis should
include the
         weighting of the evidence that is commensurate with the extent to
which it is objectively
         verified. For any tax-planning strategies that you are relying on in
your analysis, please
         ensure that your discussion provides us with a detailed explanation of
the nature and any
         uncertainties, risk, and assumptions for those strategies. Please
refer to ASC 740-10-30-
         16 - 740-10-30-25, ASC 740-10-55-39 - 740-10-55-48, and ASC
740-10-55-120 - 740-10-
         55-123 for guidance. Please also address this comment as it relates to
your net deferred
         tax assets as of June 30, 2018.
        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.

        You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or
Jeanne Baker,
Assistant Chief Accountant, at (202) 551-3691, if you have questions regarding
comments on the
financial statements and related matters. Please contact Sergio Chinos, Staff
Attorney, at (202)
551-7844, or Sherry Haywood, Staff Attorney, at (202) 551-3345, with any other
questions.



                                                             Sincerely,
FirstName LastNameJoel Mostrom
                                                             Division of
Corporation Finance
Comapany NameBabcock & Wilcox Enterprises, Inc.
                                                             Office of
Manufacturing and
September 13, 2018 Page 2                                    Construction
FirstName LastName