A layer of nanocrystals for use in making EEPROMs is made by creating a matrix of silicon seeds in annealed silicon oxide atop a thin silicon dioxide layer. Then nanocrystals are grown on the seeds by vapor deposition of silane in a reactor until a time before agglomeration occurs as silicon atoms crystallize on the silicon seeds to form a layer of non-contacting nanocrystals. A protective insulative layer is then deposited over the nanocrystal layer.