The passivity of Alloy 22 is attributed to the presence of a chromium-rich oxide film. However, in some alkaline environments, such as simulated concentrated water, a chromium-rich passive film has not been observed. It is believed that the chromium-rich passive film should be present because of the measured low corrosion rates. A silica/carbon contamination layer noted on the surface of Alloy 22 (UNS N06022) could also contribute to the observed low corrosion rates. A thermodynamic analysis was conducted to analyze the formation of the chromium-rich passive film. Solution compositions examined by other investigators where chromium oxides were not detected have been evaluated with commercial software to develop potential-pH diagrams. The thermodynamic data indicate that a chromium-nickel oxide (NiCr2O4) is thermodynamically stable and may be a likely contributor to the observed low corrosion rates. Failure to observe the film is probably due to it being masked by a thick outer layer on the surface in combination with the dimensions of the film.