An Electrically Erasable Programmable Read Only Memory (EEPROM) memory cell and a method of operation are disclosed for creating an EEPROM memory cell in a standard CMOS process. A single polysilicon layer is used in combination with lightly doped MOS capacitors. The lightly doped capacitors employed in the EEPROM memory cell can be asymmetrical in design. Asymmetrical capacitors reduce area. Further capacitance variation caused by inversion can also be reduced by using multiple control capacitors. In addition, the use of multiple tunneling capacitors provides the benefit of customized tunneling paths.