A method of operating a memory cell by applying a positive voltage to the gate sufficient to cause hole tunneling from the gate toward the charge storage layer is disclosed. The method is applied to a memory cell including a semiconductor layer having at least two source/drain regions disposed below a surface of the semiconductor layer and separated by a channel region. The memory cell also has a lower insulating layer disposed above the channel region; a charge storage layer disposed above the lower insulating layer; an upper insulating multi-layer structure disposed above the charge storage layer. The upper insulating multi-layer structure comprises a lower dielectric layer and an upper nitride layer disposed above the lower dielectric layer and the memory cell has a gate disposed above the upper insulating multi-layer structure.