Abstract In complex systems such as a nuclear and chemical plant, it is well known that the provision of understandable procedures that allow operators to clarify what needs to be done and how to do it is one of the requisites to secure their safety. As a previous study in providing understandable procedures, the step complexity (SC) measure that can quantify the complexity of procedural steps in emergency operating procedures (EOPs) of a nuclear power plant (NPP) was suggested. However, the necessity of additional complexity factors that can consider a cognitive aspect in evaluating the complexity of procedural steps is raised. To this end, the comparisons between operators' performance data measured by the form of a step performance time with their behavior in carrying out the prescribed activities of procedural steps are conducted in this study. As a result, two kinds of complexity factors (the abstraction level of knowledge and the level of engineering decision) that could affect an operator's cognitive burden are identified. Although a well-designed experiment is indispensable for confirming the appropriateness of the additional complexity factors, it is strongly believed that the change of operators' performance data can be more authentically explained if the additional complexity factors are taken into consideration.