November 8, 2018

Herbjorn Hansson
Chief Executive Officer
Nordic American Tankers Ltd
LOM Building
27 Reid Street
Hamilton HM 11
Bermuda

       Re: Nordic American Tankers Ltd
           Form 20-F for Fiscal Year Ended December 31, 2017
           Filed May 15, 2018
           File No. 001-13944

Dear Mr. Hansson:

       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 20-F filed on May 15, 2018

Item 5. Operating and Financial Review and Prospects
H. Critical Accounting Estimates
Vessel Impairment, page 38

1.    Considering that your market capitalization is significantly lower than
equity as of June
      30, 2018 and given the significant decline in revenues and operating
results through June
      30, 2018, supplementally advise us of whether you performed an updated
interim
      impairment test of your vessels pursuant to the guidance in Topic ASC
360-10. If so,
      provide us with your conclusions/results, including the nature and amount
of all
      significant assumptions. If you did not perform an analysis subsequent to
December 31,
 Herbjorn Hansson
FirstName LastNameHerbjorn Hansson
Nordic American Tankers Ltd
Comapany 8, 2018
November NameNordic American Tankers Ltd
November 8, 2018 Page 2
Page 2
FirstName LastName
         2017, please explain why you do not believe the significant decline in
revenues resulting
         from decreased TCE rates experienced during the first six months of
2018 as compared to
         the comparable period of the prior year represents a significant
adverse change in business
         climate that could affect the value of the vessels, which would
trigger an updated
         impairment analysis pursuant to ASC Topic 360-10. Finally, tell us if
you intend to
         perform an analysis prior to year end 2018.
2.       We note from your press release furnished on Form 6-K on August 15,
2018 that, towards
         the end of the 2nd quarter, you entered into several agreements to
sell 8 Suezmax vessels
         and these vessels have now been delivered to their respective new
owners. Please tell
         us the amount of any loss or gain you have recorded on the sale of
these vessels. Also, if
         these are the vessels that were written down to fair value as of
December 31, 2017, tell us
         how the consideration received for these vessels compares to their
fair value as of
         December 31, 2017.
Item 15. Controls and Procedures
A. Disclosure Controls and Procedures, page 64

3.       Please revise to indicate that it was management, including the Chief
Executive Officer
         and the Chief Financial Officer, that assessed the disclosure controls
and procedures, not
         the company. Refer to Item 307 of Regulation S-K and SEC Release No.
33-8810. In
         addition, please clarify that any remedial efforts are made towards a
broader spectrum of
         issues and not just going concern.
Note 10. Long-Term Debt
Credit Facility and Financing, page F-17

4.       Please provide us with an update on the status of the revolving credit
facility (i.e., the
         Backstop facility), such as any instances of default and covenant
violations as of the date
         of your response letter. Furthermore, in accordance with the
requirements of Rule 4-
         08(e)(1) of Regulation S-X, revise to disclose in the notes to the
financial statements the
         nature of any restrictions on the company's ability to pay dividends,
as applicable.
Note 16. Financial Instruments and Other Fair Value Disclosures, page F-21

5.       We note that you have provided a table with the carrying value and
estimated fair value of
         assets and liabilities measured at fair value on a recurring basis.
Please revise to also
         include the disclosures required by ASC 820-10-5-2 for assets and
liabilities measured at
         fair value on a non-recurring basis, such as your impairment of
vessels and goodwill
         during 2017.
       In closing, 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.
 Herbjorn Hansson
Nordic American Tankers Ltd
November 8, 2018
Page 3

        You may contact Effie Simpson at (202) 551-3346 or Claire Erlanger at
(202) 551-3301
with any questions.



FirstName LastNameHerbjorn Hansson                       Sincerely,
Comapany NameNordic American Tankers Ltd
                                                         Division of
Corporation Finance
November 8, 2018 Page 3                                  Office of
Transportation and Leisure
FirstName LastName