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                                July 23, 2020

       Scott A. Tozier
       Chief Financial Officer
       ALBEMARLE CORPORATION
       4250 Congress Street, Suite 900
       Charlotte, North Carolina
       28209

                                                        Re: ALBEMARLE
CORPORATION
                                                            Form 10-K for
Fiscal Year Ended December 31, 2019
                                                            Filed February 26,
2020
                                                            File No. 001-12658

       Dear Mr. Tozier:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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

       Raw Materials and Significant Supply Contracts, page 4

   1.                                                   Please tell us if you
have considered additional mining property disclosure pursuant to the
                                                        Instructions to Item
102 of Regulation S-K. We generally consider additional mining
                                                        property disclosure
(Industry Guide 7) to be necessary, if the total asset value of the
                                                        aggregate of all
mining/processing properties exceeds 10% of total assets. We also
                                                        consider mining
properties to include properties and related processing plants used from
                                                        the point of mineral
extraction to the first point of material sales. In addition, your ability
                                                        to continue to reliably
and economically secure raw materials, upon which rests your
                                                        business plan of adding
value and your ultimate profitability, would likely be viewed by
                                                        most investors as
material. In your response, please tell us how you measure the
                                                        materiality and the
significance of your mining properties. Based on your response we
                                                        may have additional
comments.
 Scott A. Tozier
FirstName  LastNameScott A. Tozier
ALBEMARLE       CORPORATION
Comapany
July       NameALBEMARLE CORPORATION
     23, 2020
July 23,
Page  2 2020 Page 2
FirstName LastName
2.       Please disclose the information required under paragraph (b) of
Industry Guide 7 for all
         your material properties listed under this heading. For any properties
identified that are
         not material, please include a statement to that effect, clarifying
your intentions. For each
         material property, include the following information:

                The location and means of access to your property, including
the modes of
              transportation utilized to and from the property.

                Any conditions that must be met in order to obtain or retain
title to the property,
              whether you have surface and/or mineral rights.

                A brief description of the rock formations and mineralization
of existing or potential
              economic significance on the property.

                A description of any work completed on the property and its
present condition.

                The details as to modernization and physical condition of the
plant and equipment,
              including subsurface improvements and equipment.

                A description of equipment, infrastructure, and other
facilities.

                The current state of exploration of the property.

                The total costs incurred to date and all planned future costs.

                The source of power and water that can be utilized at the
property.

                If applicable, provide a clear statement that the property is
without known reserves
              and the proposed program is exploratory in nature.

         You may refer to Industry Guide 7, paragraphs (b) (1) through (5), for
specific guidance
         pertaining to the foregoing, available on our website at the following
address:
         www.sec.gov/about/forms/industryguides.pdf
3.       Please disclose your annual mine production. See Instruction 3 to Item
102 of Regulation
         S-K.
Summary of Critical Accounting Policies and Estimates, page 38

4.       We note your disclosure that life-of-mine assets are amortized over
proven and probable
         reserves using the units of production methodology. Please expand your
disclosure to
         state your updated proven and/or probable reserve estimates for each
material mining
         property. Mining properties may include your In-Situ Leach (ISL),
mineral brine, and/or
         conventional mining operations.

         In closing, we remind you that the company and its management are
responsible for the
 Scott A. Tozier
ALBEMARLE CORPORATION
July 23, 2020
Page 3

accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

        You may contact George K. Schuler at (202) 551-3718 or Terence O'Brien
at (202) 551-
3355 if you have questions regarding comments on the financial statements and
related matters.



FirstName LastNameScott A. Tozier                          Sincerely,
Comapany NameALBEMARLE CORPORATION
                                                           Division of
Corporation Finance
July 23, 2020 Page 3                                       Office of Energy &
Transportation
FirstName LastName