X operates a manufacturing facility.
In the past, X's manufacturing operations had produced waste by-products in the course of its operations. X excavated a hole in the ground large enough to gain access to the old USTs. X then drained the waste from the old USTs and placed it in a temporary repository. X then lifted the old USTs out of the hole, cleaned them, and disposed of them at an appropriate disposal facility. In the same taxable year, X placed the new USTs in the same hole, and transferred the waste from the temporary repository into the new USTs.