Abstract: Statistical Energy Analysis(SEA)is an effective method for solving high frequency structural vibration and acoustic radiation problems. When we use it to analyze submerged structures, it is necessary to consider the actions of fluid as'heavy fluid' relative to structures, which differs from when it is used in the air. The simple model of a submerged cylindrical shell is used to calculate at a higher frequency using FEM/BEM. The SEA and FEM method are then used to calculate the radiation sound pressure level, verifying the accuracy of the SEA prediction for submerged structures. The classified method of subsystems and the effect of the error of the internal loss factor on the accuracy of the results are explored. The calculated results of SEA and FEM/BEM are very different below 400 Hz, and basically the same above 400 Hz. The error caused by the division of different subsystems is about 5 dB. The error in the calculation results caused by the error of the internal loss factor is 2-3 dB. It is possible to use SEA to calculate the radiated noise of an underwater cylindrical shell when the modal density is high enough.For the cylindrical shell, dividing the subsystems along the circumference is not reliable at a low frequency, as it may lead to inaccurate calculation results. At a high frequency, it is more accurate to divide the subsystems along the circumference than the axle. For subsystems with high energy, the internal loss factor has a greater effect on the simulation results, so a more accurate way should be taken to determine the internal loss factor of subsystems with high energy.