December 10, 2015

By EDGAR

Jay Ingram

Legal Branch Chief

Office of Manufacturing and Construction

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-4561

Dear Mr. Ingram:

In further response to comment no. 2 of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in your letter dated October 8, 2015 and comment no. 1 of the Staff set forth in your letter dated August 28, 2015 with regard to the above-referenced Registration Statement on Form S-3 and the above-referenced Form 10-K (“Form 10-K”) and Form 10-Q of Synalloy Corporation (the “Company” or “Synalloy”), we submit on behalf of the Company the following responses as supplements to the Company’s response letters dated October 23, 2015 and September 25, 2015.

CALIFORNIA \ COLORADO \ CONNECTICUT \ DELAWARE \ GEORGIA \ MARYLAND \ MASSACHUSETTS

MICHIGAN \ NEVADA \ NEW JERSEY \ NEW YORK \ PENNSYLVANIA \ TEXAS \ VIRGINIA \ WASHINGTON, DC

ATTORNEYS AT LAW \ WWW.LECLAIRRYAN.COM

Mr. Jay Ingram

U.S. Securities and Exchange Commission

December 10, 2015

Page 2

Comment No. 2, Commission Letter dated October 8, 2015

Synalloy Corporation Form 10-K for Fiscal Year Ended January 3, 2015

Note 13: Industry Segments, page 46

Supplemental Response: In connection with responding to the Staff’s questions regarding industry segments in our response letters dated October 23, 2015 and September 25, 2015 and our telephone conversation with the Staff on November 6, 2015, the Company has further assessed its determination of operating and reportable segments and concluded that the presentation of two reportable segments (Metals and Specialty Chemicals) is more accurately supported by our revised conclusion that the Company is comprised of only two operating segments (Metals and Specialty Chemicals).

As the Company functions, the two historical reporting and operating segments are comprised of three components in the Metals reportable/operating segment (i.e. Bristol Metals, LLC (“BRISMET”), Palmer of Texas Tanks, Inc. (“Palmer”), and Specialty Pipe and Tube, Inc. (“SPT”)) and two components in the Specialty Chemicals reportable/operating segment (i.e. CRI Tolling, LLC (“CRI”) and Manufacturers Chemicals, LLC (“MC”)). Upon further review, we have concluded that our organizational and management structure has evolved through the addition of a president for each of the Metals and Specialty Chemicals segments (each a “President” and collectively the “Presidents”). The activities of the Company’s chief operating decision maker (the “CODM” or “CEO”) and those of the segment Presidents in assessing the operating performance and making decisions about resource allocations to and within our Metals and Specialty Chemicals segments leads us to conclude that the President of Metals and the President of Specialty Chemicals are segment managers that report directly to the CODM. We believe that this designation is supported by the definitions and guidance set forth in Accounting Standard Codification 350, in support of maintaining a position that we have two reportable/operating segments.

This assessment has involved a more thorough consideration by management of how financial information is utilized and decisions are made within the organization. Included below is an outline of the respective responsibilities of the Company’s CEO and the segment Presidents.

The CEO relationship with the segment Presidents is defined by the following:

Mr. Jay Ingram

U.S. Securities and Exchange Commission

December 10, 2015

Page 3

Comment No. 1, Commission Letter dated August 28, 2015

Synalloy Corporation Form 10-K for Fiscal Year Ended January 3, 2015

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Policies and Estimates, page 18

Goodwill, page 19

Supplemental Response: Having provided a conclusive response to the Staff’s questions regarding the level of goodwill assessment in our response letter dated September 25, 2015, the Company would like to clarify that the level at which goodwill impairment testing is performed was subjected to further review in conjunction with our operating segment definition described

Mr. Jay Ingram

U.S. Securities and Exchange Commission

December 10, 2015

Page 4

above. The Company will perform its annual impairment tests at the reporting unit level in the Metals reporting/operating segment (BRISMET, Palmer and SPT). The Company will perform its annual impairment tests in the Specialty Chemicals reporting/operating segment on a combined basis for CRI and MC because we have concluded that CRI and MC are economically similar to be combined as one reporting unit.

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Please contact me at (804) 343-4079 or John C. Selbach at (804) 343-4388 should you require further information or if you have any questions.