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required by law. Golden Press, 235 P.2d at 594. The Board acted contrary to law by imposing <br />significant civil penalties and a cease - and - desist order for Cotter's alleged failure to comply with <br />an order that could be (and was) given widely divergent interpretations. <br />The extreme imprecision in the August 2010 Order was only compounded in the <br />December 2010 Order. It states, without explanation, "The Board hereby issues a cease and <br />desist order to the Operator." AR:0170. Although the Hearing amply demonstrated the lack of <br />clarity as to what. the August 2010 Order required Cotter to do before the August 31, 2010 <br />deadline, the Board's December 2010 Order makes no attempt to define the precise conduct from <br />which Cotter must "cease and desist." Even the Division recognized this deficiency — it <br />requested that the Board revise its draft cease - and - desist order to specifically "enjoin[] the <br />operator from continuing to fail to comply with all outstanding corrective actions and to pay civil <br />penalties mandated by the Mined Land Reclamation Board Order of August 11, 2010." <br />AR:0161. The Board, however, rejected the Division's request, again with no explanation. <br />Given the inherent ambiguity in the August 2010 Order, followed by the December 2010 <br />Order's completely open -ended admonition to "cease and desist," the Court must hold the <br />December 2010 Order unlawful because both it and the prior order it enforces are too vague to <br />be enforceable. <br />uranium. AR:0248:9 -12. Because of Cotter's additional efforts, Cotter had treated close to 8 <br />million gallons of water and removed over 311 pounds of uranium at the time of the Hearing. <br />AR:0248:9 -15. <br />8 Even if the Board had made the revision requested by the Division, the order would <br />have done nothing to resolve the lingering confusion as to the precise conduct required to <br />comply with the August 2010 Order. <br />24 <br />