May 6, 2026

Christopher Thome
Chief Financial Officer
Graham Corporation
20 Florence Avenue
Batavia, New York 14020

       Re: Graham Corporation
           Registration Statement on Form S-3
           Filed April 30, 2026
           File No. 333-295458
Dear Christopher Thome:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

       Please contact Uwem Bassey at 202-551-3433 or Jeff Kauten at
202-551-3447 with any
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology
cc:    Alexander R. McClean