Pennsylvania Federal Court Clarifies HSCA Statute of Limitations and “Response Costs” Under HSCA and CERCLA

April 2, 2026

Sean F. Fahy, Esq.

MGKF Litigation Blog

A recent decision from the United States District Court for the Middle District of Pennsylvania offers insight into cost recovery claims under both the Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”) and Pennsylvania’s Hazardous Sites Cleanup Act (“HSCA”). On March 6, 2026, in Blettner Avenue, LLC v. Central Uniform Services, Inc., the Middle District denied Defendants Rental Uniform Services, Inc. (“Rental Uniform Services”) and Cintas Corporation (“Cintas”)’s motion for summary judgment as to Plaintiff Blettner Avenue, LLC (“Blettner”)’s HSCA claim, shedding light on HSCA’s time limitation provision and the scope of “response costs” under the statute. On the other hand, the Court granted Defendants’ motion for summary judgment as to Blettner’s CERCLA claim, finding Blettner failed to comply with national consistency plan (“NCP”) requirements. The decision provides useful insight for practitioners to consider regarding statute of limitation under HSCA, the scope of “response costs” under HSCA and CERCLA, and NCP compliance under CERCLA.

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