Exhibit 8


                                                    September 10, 2001

PSEG Power LLC
80 Park Plaza
Newark, NJ 07101

RE:   PSEG Power LLC
      Exchange Offer for
           $500,000,000 6-7/8 % Senior Notes due 2006;
           $800,000,000 7-3/4 % Senior Notes due 2011; and
           $500,000,000 8-5/8 % Senior Notes due 2031

      Certain Federal Income Tax Considerations

Ladies and Gentlemen:

      I  am  Associate  General  Counsel  of  Public  Service  Enterprise  Group
Incorporated  and in that  capacity  have acted as counsel for its  wholly-owned
subsidiary,   PSEG  Power  LLC,  a  Delaware  limited   liability  company  (the
"Company"),  in connection with the  preparation of a Registration  Statement on
Form S-4 (the "Registration Statement), which is being filed with the Securities
and  Exchange  Commission  under the  Securities  Act of 1933,  as amended  (the
"Act"),  relating  to  an  offer  (the  "Exchange  Offer")  to  exchange  up  to
$500,000,000  aggregate  principal  amount of the Company's 6-7/8 % Senior Notes
due 2006,  $800,000,000  aggregate  principal  amount of the  Company's  7-3/4 %
Senior  Notes  due 2011  and  $500,000,000  aggregate  principal  amount  of the
Company's  8-5/8 % Senior  Notes  due  2031,  respectively,  (collectively,  the
"Exchange  Notes") for a like principal amount of its outstanding 6-7/8 % Senior
Notes due 2006, 7-3/4 % Senior Notes due 2011 and 8-5/8 % Senior Notes due 2031,
respectively, (collectively, the "Original Notes").

      I, or  members  of my  staff,  have  reviewed  a copy of the  Registration
Statement and such other documents as I have deemed  necessary or appropriate as
a basis for the opinions set forth below.

      Based on the foregoing,  I am of the opinion that if the offer and sale of
the Exchange  Notes are conducted in the manner  described in the Prospectus and
if the terms of the  Exchange  Notes  are as  contemplated  by the  Registration
Statement,  then the exchange of the Original  Notes for Exchange Notes pursuant
to the Exchange Offer will


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not  constitute a significant  modification  of the terms of the Original  Notes
and, therefore, such exchange will not constitute an exchange for federal income
tax purposes and will have no federal income tax  consequences to holders of the
Original Notes.

      The opinion expressed herein is based upon existing statutory, regulatory,
and judicial authority, any of which may be changed at any time with retroactive
effect.  In addition,  my opinion is based solely on the  documents  that I have
examined,  the authenticity of which I assume,  such other information as I have
deemed necessary or appropriate.  My opinion cannot be relied upon if any of the
facts  contained  in  such  documents  or  information  is,  or  later  becomes,
inaccurate.  Finally,  my opinion is  limited  to the tax  matters  specifically
covered herein, and I have not been asked to address, nor have I addressed,  any
other tax consequences of the Exchange Offer.

      I hereby  consent  to the  filing  of this  opinion  as  Exhibit  8 to the
Registration Statement. I also consent to the reference to me under the captions
"Federal Income Tax  Considerations"  and "Legal  Opinions" in the  Registration
Statement.

                                                       Very truly yours,

                                                       James T. Foran
                                                       Associate General Counsel



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