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United States securities and exchange commission logo
May 27, 2020
David S. Black
Senior Vice President and Chief Financial Officer
BWX Technologies, Inc.
800 Main Street, 4th Floor
Lynchburg, Virginia 24504
Re: BWX Technologies,
Inc.
Form 10-K for
Fiscal Years Ended December 31, 2019
Filed February 24,
2020
File No. 001-34658
Dear Mr. Black:
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 Fiscal Years Ended December 31, 2019
Note 10 -- Commitments and Contingencies
Environmental Matters, page 83
1. We note that you have
been identified as a potentially responsible party at various cleanup
sites under CERCLA,
which you believe ultimately "will not have a material adverse
effect on our
consolidated financial condition, results of operations or cash flows in any
given year." We also
note you have recorded asset retirement obligations related to the
nuclear remediation
efforts in your Nuclear Operations Group and Nuclear Power Group
segments. SAB Topic 5:Y
states that product and environmental remediation liabilities
are of such
significance that detailed disclosures regarding the judgments and assumptions
underlying the
recognition and measurement of the liabilities are necessary to inform
readers fully regarding
the range of reasonably possible outcomes that could have a
material effect on your
financial condition, results of operations, or liquidity. In this
regard, please explain
your assessment of your exposure to environmental losses in
David S. Black
BWX Technologies, Inc.
May 27, 2020
Page 2
determining whether there is a reasonable possibility that a material
loss exceeding
amounts already recognized may have been incurred. Tell us why it is
not necessary for
you to provide disclosure that addresses the examples in the
Interpretive Response to
Question 2 of SAB Topic 5:Y with respect to any exposure to material
unrecorded
remediation liabilities.
2. Regarding your liability as a potentially responsible party at various
cleanup sites, we note
your materiality assessment was made on the basis of your relative
contribution of waste
to each site. In future filings please clarify if you also considered
the financial solvency of
the other responsible parties when making your materiality assessment,
and advise us.
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 Joseph Cascarano, Senior Staff Accountant, at (202)
551-3376 or
Robert S. Littlepage, Accountant Branch Chief, at (202) 551-3361 with any
questions.
FirstName LastNameDavid S. Black Sincerely,
Comapany NameBWX Technologies, Inc.
Division of
Corporation Finance
May 27, 2020 Page 2 Office of
Technology
FirstName LastName