This paper proposes a simplified elastic-plastic analysis procedure using the penalty factors presented in the Code Case N-779 for strain-based fatigue assessment of nuclear safety class 1 components under severe seismic loads such as safety shutdown earthquake and beyond design-basis earthquake. First, a simplified elastic-plastic analysis procedure for strain-based fatigue assessment of nuclear safety class 1 components under the severe seismic loads was proposed based on the analysis result for the simplified elastic-plastic analysis procedure in the Code Case N-779 and the stress categories corresponding to normal operation and seismic loads. Second, total strain amplitude was calculated directly by performing finite element cyclic elastic-plastic seismic analysis for a hot leg nozzle in pressurizer surge line subject to combined loading including deadweight, pressure, seismic inertia load, and seismic anchor motion, as well as was derived indirectly by applying the proposed analysis procedure to the finite element elastic stress analysis result for each load. Third, strain-based fatigue assessment was implemented by applying the strain-based fatigue acceptance criteria in the ASME B&PV Code, Sec. III, Subsec. NB, Article NB-3200 and by using the total strain amplitude values calculated. Last, the total strain amplitude and the fatigue assessment result corresponding to the simplified elastic-plastic analysis were compared with those using the finite element elastic-plastic seismic analysis results. As a result of the comparison, it was identified that the proposed analysis procedure can derive reasonable and conservative results.