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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
       September 5 , 2014

Via E -mail

Jeffrey Glajch
Chief Financial Officer
Graham Corporation
20 Florence Avenue
Batavia, New York  14020

 Re: Graham Corporation
  Form 10 -K for the fis cal year ended March  31, 201 4
  Filed June 4, 2014
  File No. 001-8462

Dear M r. Glajch :

We have reviewed your filing and have the following comment s.  In our
comment s, we may ask you to provide us with information so we may better understand
your disclosure.

Please respond to this letter within ten busine ss days  by providing the requested
information or by advising us when you will provide the requested response.  If you do
not believe our comment s apply  to your facts and circumstances , pleas e tell us why in
your response.

After reviewing the information you pro vide in response to these  comment s, we
may have additional comments.

Form 10 -K for the fiscal year ended March 31, 2014

Item 7.   Management’s Discussion and Analysis of Financial Condition an d Results  of
Operations

Results of Operations, Fiscal 2014 compared with Fiscal 2013, page 24

1. We reference the discussion of the fluctuation in sales recorded for fiscal 2014 as
compared to fiscal 2013.   While we see that you describe the composition of
sales between domestic and international and by  market, we do not see where you
have provided a discussion of the reasons for the variances each period or how the
described fluctuations impacted revenues recorded for the period.   In future

Jeffrey Glajch
Graham Corporation
Septe mber 5 , 2014
Page 2

 filings please include enhanced disclosure to provide investor s with an
understanding of  any known trends or uncertainties that have had or that you
expect  will have a material favorable or unfavorable impact on net sales or
revenues or income from continuing operations , as required by Item 303 (A) (3)
of Regulation S-K.

2. As a related matter, we note the discussion on page 28 about certain projects that
you expect to have a significant impact on your revenues and earnings.  Please tell
us how you have considered whether to provide more specific detail about the
status, impact on your financial statements and expected ti ming of the completion
of material projects.  In that regard, please tell us your consideration of providing
additional disclosure that discusses the underlying progress on the major projects
during th e reporting periods as well as their actual impact on your financial
statements with greater specificity.

Consolidated Financial Statements

Note 14.  Segment Information, page 63

3. We reference the statement on page 63 that your operating segments meet t he
requirement for aggregation.   Please identify your operating segments and provide
us with your analysis of the criteria presented in FASB ASC 280 -10-50-11.  In
addition, please clarify the nature of the revenues presented within the line item
“all other ” in the table on page 63.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchange Act rules require.  Since the compa ny
and its management are in possession of all facts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy of the disclosures they have made.

 In responding to our comments, please provide a written statement from the
company acknowledging that:

 the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
 staff comments or changes to disclosure in response to staff comments do
not foreclose the Commission from taking any action with respect to  the
filing; and
 the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Jeffrey Glajch
Graham Corporation
Septe mber 5 , 2014
Page 3

  You may contact Kristin Lochhead, Senior Accountant,  at (202) 551 -3664  or me
at (202) 551 -3676 if you have questions regarding comments on the financial statements
and related matters.  Please contact Martin James, Senior Assistant Chief Accountant, at
(202) 551 -3671  with any other questions.

Sincerely,

/s/ Brian Cascio

Brian Cascio
Accounting Branch Chief