Exhibit 8

                                                     August 8, 2002

PSEG Power LLC
80 Park Plaza
Newark, NJ 07101

RE:  PSEG Power LLC
     Exchange Offer for $600,000,000 6.95% Senior Notes due 2012
     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
subsidiaries,  PSEG Power LLC (the "Company"),  PSEG Fossil LLC ("Fossil"), PSEG
Nuclear LLC ("Nuclear") and PSEG Energy  Resources & Trade LLC ("ER&T"),  each a
Delaware limited  liability  company,  in connection with their 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 $600,000,000  aggregate  principal  amount of the Company's 6.95%
Senior Notes due 2012 (the "Exchange  Notes") for a like principal amount of its
outstanding  6.95%  Senior  Notes  due  2012  (the  "Original  Notes")  under an
indenture  dated as of April 16,  2001 (the  "Indenture")  between and among the
Company,  Fossil,  Nuclear,  ER&T  and The  Bank of New  York  as  Trustee  (the
"Trustee").

     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 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.


<PAGE>

     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,

                                                       /s/ James T. Foran
                                                       -------------------------
                                                       James T. Foran
                                                       Associate General Counsel


                                       2