September 9, 2019

Louis Salamone
Executive Vice President and Chief Financial Officer
Babcock & Wilcox Enterprises, Inc.
20 South Van Buren Ave
Barberton, OH 44203

       Re: Babcock & Wilcox Enterprises, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed April 2, 2019
           File No. 1-36876

Dear Mr. Salamone:

       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 the Fiscal Year ended December 31, 2018

Note 3 -- Earnings per Share, page 80

1.    Your disclosure in Note 22 indicates that your 2018 Rights Offering, as
amended, entitled
      the holders of your common stock the right to purchase 2.8 common shares
at a price of
      $2.00 per share. Please address how you determined that this rights issue
did not contain
      a bonus element that should be accounted for in accordance with ASC
260-10-55-13 and
      55-14. In this regard, the purchase price appears to be less than the
fair value of your
      common shares on April 30, 2018, the issuance date.
Note 6 -- Segment Reporting, page 86

2.    Although you disclose that you changed your primary measure of segment
profitability
      from gross profit to adjusted EBITDA, we note that you continue to
present segment gross
      profit. If your CODM also uses this measure in assessing segment
performance and
      deciding how to allocate resources, the reported measure should be that
which
 Louis Salamone
Babcock & Wilcox Enterprises, Inc.
September 9, 2019
Page 2
         management believes is determined in accordance with the measurement
principles most
         consistent with those used in measuring the corresponding amounts in
your consolidated
         financial statements. Please refer to ASC 280-10-50-28 and advise.
Additional segment
         profit or loss measures may be presented outside of your financial
statements and
         footnotes as non-GAAP measures if they comply with Regulation G and
Item 10(e) of
         Regulation S-K.
        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 Jenn Do at (202) 551-3743 or Jeanne Baker at (202)
551-3691 if you
have any questions.



                                                            Sincerely,
FirstName LastNameLouis Salamone
                                                            Division of
Corporation Finance
Comapany NameBabcock & Wilcox Enterprises, Inc.
                                                            Office of
Manufacturing and
September 9, 2019 Page 2                                    Construction
FirstName LastName