STARK, Circuit Judge.

Dr. Ruth A. Etzel petitions for review of two final decisions of the United States Merit Systems Protection Board (“Board”). In the first decision, the Board found Dr. Etzel failed to show that she made a protected disclosure under the Whistleblower Protection Act (“WPA”) contributing to an adverse personnel action. Etzel v. EPA, No. DC-1221- 19-0827-W-2, 2022 WL 1204453 (M.S.P.B. Apr. 18, 2022). In the second decision, the Board determined that she failed to raise a nonfrivolous allegation of Board jurisdiction with respect to her pay reduction. Etzel v. EPA, No. DC-3443-21-0391-I-1, 2022 WL 1204454 (M.S.P.B. Apr. 18, 2022). We affirm.

I A Dr. Etzel, a pediatrician and environmental epidemiol- ogist, was the Director of the Office of Children’s Health Protection (“OCHP”) at the United States Environmental Protection Agency (“EPA”) from January 2015 to May 2019, a position in the Senior Executive Service (“SES”). While in that position, she participated in the development of the Federal Lead Strategy (“Strategy”), a comprehensive national plan designed to eliminate childhood exposure to lead. In early 2018, Dr. Etzel learned that the EPA did not want the Strategy to contain new enforcement measures and instead intended for it to repackage what was already being done. She considered this approach to be inadequate to ensure children would be protected from lead exposure. The Strategy was ultimately released as the “Federal Lead Action Plan” in December 2018.

On September 25, 2018, shortly before the release of the Strategy, Dr. Etzel was placed on a temporary administrative leave. On October 9, she received a formal notifi- cation of investigation, which explained that “allegations of inappropriate conduct” had been made against her and that she would be on investigative leave “for up to 30 work days.” J.A. 466-67. On October 18, Dr. Etzel notified the EPA through her attorney that she believed her investigative leave was “improper under federal law.” J.A. 1454.

During that same month, Dr. Etzel appeared on two television programs. First, on October 15, she was interviewed on CBS This Morning, during which she stated that “a national strategy to remove lead from children’s environments . . . stalled;” she added that she had been told by an EPA official that any new regulation “wouldn’t fly.” J.A. 1608. She also said that “the government has absolutely no intention of taking any action toward seriously changing lead in children’s environments.” Id. In response to being asked “[w]hat does that mean for the kids?” she responded: “[i]t basically means that our kids will continue to be poi- soned.” Id.

The next day, Dr. Etzel appeared on CNN. She told the CNN interviewer that the EPA had “got rid of” her because it “didn’t take the protection of children’s health seriously.” J.A. 3262. Further, according to Dr. Etzel, the EPA leadership at the time did not “seem to adhere to the EPA mis- sion, which has always been to protect both human health and the environment.” Id.

In November 2018, Dr. Etzel received her fiscal year 2018 performance review, which rated her at “Level 1,” an “Unsatisfactory” performance level. J.A. 1786. That overall rating resulted from a “Level 1” “Unsatisfactory” rating she was given for the critical element of “Leading People.” Id. Dr. Etzel’s intra-agency appeal of the rating decision was denied in March 2019.

On March 21, 2019, Dr. Etzel was informed by the EPA that the investigation into her alleged “inappropriate conduct” had concluded with a finding of lack of substantia- tion, meaning her investigative leave would end on March 25. She was also told that she would be removed from the SES and placed in a civil service GS-15 position effective April 28. Dr. Etzel’s SES detail was later extended to May 25, during which time she remained part of the SES and was paid a salary at an SES rate.

On May 3, 2019, EPA informed Dr. Etzel that her SES pay would be reduced by 10% based on her “Unsatisfactory” performance rating for fiscal year 2018. On May 17, she received a written decision with more detailed explanations for her pay reduction. That written decision also advised Dr. Etzel that she had seven days to request reconsideration. On May 21, the EPA implemented the 10% pay reduction, decreasing her annual salary from $188,919 to $170,028. On May 24, Dr. Etzel requested reconsideration of the pay reduction, contending that the agency violated its regulations by implementing the pay reduction before she had the opportunity to request reconsideration. The reconsideration request was eventually denied on November 20.

In the meantime, on May 26, 2019, Dr. Etzel’s SES detail was terminated and she was appointed to a GS-15 position in the Office of Water.

B Dr. Etzel filed a complaint with the Office of Special Counsel (“OSC”), alleging she had been retaliated against for making disclosures that were protected under the WPA. The OSC’s investigation was terminated on July 8, 2019, at which point Dr. Etzel received a “right to sue” letter, allowing her to file an Individual Right of Action (“IRA”) with the Board. Dr. Etzel did so on September 10, 2019 (the “Whistleblower Appeal”). Administrative Judge (“AJ”) Weiss, who was originally assigned to the Whistleblower Appeal, determined that the Board had jurisdiction over it.

On August 3, 2020, in response to certain of Dr. Etzel’s discovery requests, the EPA provided her with privilege logs. On September 18, AJ Weiss issued an order schedul- ing a prehearing conference for October 15. Two days later, Dr. Etzel filed a motion to continue the prehearing conference, indicating that she intended to file a motion to compel discovery, which prompted AJ Weiss to suspend the case until October 31, to allow the parties “additional time to resolve outstanding discovery issues.” J.A. 607. During a status call on December 10, the EPA noted that Dr. Etzel had filed no motion to compel and contended that any such motion would now be untimely. AJ Weiss then entered an order in which he “hereby granted” Dr. Etzel until December 18 to file a motion to compel. ^[1] J.A. 610. On December Dr. Etzel contends that the Board erred in finding the disclosures she made during her October 2018 appearances on CBS and CNN, about EPA’s purported lack of intent to effectively address lead poisoning in children’s environments, did not evidence a substantial and specific danger to public health and safety. We are not persuaded.

“[T]he inquiry into whether a disclosed danger is sufficiently substantial and specific to warrant protection under the WPA is guided by several factors, among these: (1) the likelihood of harm resulting from the danger; (2) when the alleged harm may occur; and (3) the nature of the harm, i.e, the potential consequences.” Chambers v. Dep’t of Interior, 602 F.3d 1370, 1376 (Fed. Cir. 2010) (internal quotation marks omitted) (“Chambers II”). We have explained that the first two factors “affect the specificity of the alleged danger, while the nature of the harm – the potential consequences – affects the substantiality of the danger.” Chambers v. Dep’t of Interior, 515 F.3d 1362, 1369 (Fed. Cir. 2008) (“Chambers I”). Applying these factors, we have found a danger to be sufficiently “substantial and specific,” such that a disclosure about it warrants protection under the WPA, when the disclosure “concerned specific allegations or evidence either of actual past harm or of detailed circumstances giving rise to a likelihood of impending harm.” Chambers II, 602 F.3d at 1376.

For example, in Chambers II, 602 F.3d at 1379, we held that the petitioner’s disclosure that traffic accidents increased on the Baltimore-Washington Parkway, which often had two officers on patrol instead of the recommended four, evidenced a substantial and specific danger to public Dr. Etzel next contends that her October 2018 statement to the EPA that her investigative leave was illegal (“October Disclosure”) is a protected disclosure under the WPA. Dr. Etzel’s primary argument is that the Board was wrong to conclude she could not, on October 18, 2018, have had a reasonable belief that a law had been violated because, as of that date, she had not yet been on investigative leave for more than 30 work days – and administrative leave of up to 30 work days is expressly permitted under the Administrative Leave Act, 5 U.S.C. § 6329b (2016). According to Dr. Etzel, she “did make disclosures about the illegality of her investigative leave well after 30 days,” including in her November 28, 2018 complaint to the OSC (“November Disclosure”), and on December 19 and 21, 2018 (“December Disclosure”). Petitioner’s Br. at 31-32.

Dr. Etzel’s contentions are unavailing. The inquiry as to the reasonableness of her beliefs turns on the date she made the disclosure, not the date she filed her complaint with OSC or at some still later date. See Edenfield v. Dep’t of Veterans Affs., 54 F.4th 1357, 1361 (Fed. Cir. 2022) (assessing reasonableness of speakers’ beliefs “at the time they made the disclosure”). Dr. Etzel made the disclosure for which she seeks protection on October 18, 2018, which was less than 30 work days after she had been placed on investigative leave, and therefore at a time when she could not have reasonably believed the agency acted unlawfully in that respect. Her subsequent November Disclosure and December Disclosure are not merely “additional information” or “a more detailed account of” Dr. Etzel’s October Disclosure. See Briley v. Nat’l Archives & Recs. Admin., 236 F.3d 1373, 1378 (Fed. Cir. 2001). Instead, those latter statements would be the basis for (if anything) a distinct claim. However, because Dr. Etzel did not exhaust her administrative remedies with respect to the November and December Disclosures, these disclosures cannot provide a basis on which we could find a reversible error in the Board’s decision. See McCarthy v. Merit Sys. Prot. Bd., 809 F.3d 1365, 1374 (Fed. Cir. 2016) (finding that distinct disclosures require exhaustion as to each).

Dr. Etzel next contends that the record lacks substantial evidence for the Board’s determination that her request for reconsideration of her pay reduction was not a contributing factor to any adverse personnel action she allegedly suffered. We disagree.

Substantial evidence supports the Board’s finding that Dr. Etzel’s purported lack of substantive work assignments at the Office of Water was not an adverse personnel action. In reaching this conclusion, AJ Alexander witnessed and evaluated the testimony of Ms. Deborah Nagle, Dr. Etzel’s supervisor at the Office of Water, who explained that she assigned Dr. Etzel “meaningful and plentiful work.” J.A. 35. He also considered documentary evidence of Dr. Etzel’s duties, work assignments, and work product. Based on the evidence, AJ Alexander found that Ms. Nagle “testified in a direct and straightforward manner, and her testimony was specific, detailed, and consistent with other record evidence.” Id. Even assuming substantial evidence could have supported a contrary conclusion, AJ Alexander’s decision to credit Ms. Nagle’s testimony over Dr. Etzel’s and his evaluation of the documentary record make his determination a reasonable one. See Chambers I, 515 F.3d at 1370 (finding that Board’s “credibility determinations are virtually unreviewable at this level”) (internal quotation marks omitted).

Because Dr. Etzel failed to prove she suffered from an adverse personnel action, it necessarily follows that she failed to prove that any protected disclosure she may have made (if any) was a contributing factor to an adverse personnel action.

B We turn next to Dr. Etzel’s contention that AJ Alexander abused his discretion by denying her motion to compel discovery as untimely. See generally Chambers I, 515 F.3d at 1371 (“We leave discovery and evidentiary issues to the sound discretion of the board and its officials, and will not overturn the board on such matters unless an abuse of discretion is clear and is harmful.”) (internal quotation marks omitted). Pursuant to Board regulations, “[a]ny motion for an order to compel or issue a subpoena must be filed with the judge within 10 days of the date of service of objections.” 5 C.F.R. § 1201.73(d)(3). Dr. Etzel acknowledges that her December 18, 2020 motion was filed far more than 10 days after she received the privilege logs from EPA on August 3, 2020. She insists, however, that AJ Weiss extended her filing deadline in his December 10, 2020 order, “grant[ing] [Dr. Etzel] until December 18, 2020 to file a motion to compel discovery in this matter.” J.A. 610.

Dr. Etzel’s reading of AJ Weiss’ order is not unreasonable, but neither is AJ Alexander’s alternative reading. AJ Alexander read the order as “merely set[ting] a deadline by which [Dr. Etzel] could file a motion to compel” and as making “no ruling on whether it would be otherwise timely with respect to the agency’s responses,” a determination AJ Weiss would have presumably made when, and only when, he received such a motion. J.A. 1310. The record reveals no express request by Dr. Etzel for an extension of the § 1201.73 deadline, nor any explicit grant of any extension. There is, in short, no clear error in AJ Alexander’s interpretation of AJ Weiss’ prior order and no abuse of discretion in denying the motion to compel.

C Finally, we address Dr. Etzel’s petition for review of the Board’s decision in the Pay Reduction Appeal. In this regard, the Board concluded that Dr. Etzel did not raise a nonfrivolous allegation of Board jurisdiction, reasoning (i) Dr. Etzel was a member of the SES when her pay was reduced and (ii) pay reductions for SES members are not reviewable by the Board. See 5 C.F.R. §§ 534.404(j)(1), (4). Dr. Etzel’s challenges to this analysis lack merit.

Dr. Etzel first contends that the extension of her SES detail for the purpose of reducing her pay was “a sham,” and because the EPA “could not legally act to reduce her pay under SES regulations under the circumstances,” 4 the pay reduction is reviewable under 5 U.S.C. §§ 7512(4) and 7513(d). Petitioner’s Br. at 42-43. We disagree. As Dr. Etzel recognizes, members of the SES do not come within the definition of “employee” as set forth in 5 U.S.C. § 7511(a)(1), which renders such individuals ineligible to appeal pay reductions under 5 U.S.C. §§ 7512(4) and 7513(d). Pay reductions for SES members are also made unreviewable by 5 C.F.R. § 534.404(j)(4), which provides that “[r]eductions in pay under paragraph (j) of this section are not appealable under 5 U.S.C. 7543.” It follows that because Dr. Etzel remained a member of the SES when her pay reduction was implemented on May 21, 2019, the

4 Under 5 C.F.R. § 359.705(a)(3), “[a]n appointee placed . . . in a position outside the SES (in the same or different agency) is entitled to receive basic pay at the highest of . . . [t]he rate of basic pay in effect for the appointee immediately before removal from the SES.”

Board cannot exercise jurisdiction over her appeal under 5 U.S.C. §§ 7512(4), 7513(d), or 7543(d).

Dr. Etzel cites no authority for her contention that she can meet her burden to establish Board jurisdiction by alleging (or even by proving) that an agency’s action to extend an SES detail was a “sham,” undertaken solely (and improperly) to reduce her pay without review. Dr. Etzel suggests that the EPA could have either reduced her pay or demoted her out of SES but could not do both. Yet, again, she cites no authority for this proposition, so we fail to see how it helps her show the Board had jurisdiction over her Pay Reduction Appeal.

Dr. Etzel next argues that the Board had jurisdiction under 5 U.S.C. §§ 7512(4) and 7513(d) because she had been removed from the SES by the time her pay reduction was, in her words, “finally decided,” when her request for reconsideration under 5 C.F.R. § 534.404(j)(3)(v) was denied in November 2019. Petitioner’s Br. at 45-46. But the pay reduction actually occurred back on May 21, 2019, a fact Dr. Etzel herself acknowledged. See, e.g., Petitioner’s Br. at 45-46 (“EPA improperly put the pay reduction into effect on May 21, 2019.”); id. at 46 (“EPA effectuated the pay reduction on May 21, 2019.”). Dr. Etzel cites no authority that the pertinent date is anything other than when the pay reduction is effectuated.

Dr. Etzel further contends that EPA violated 5 C.F.R. § 534.404(j)(3)(v) by implementing her pay reduction before the deadline for her to request reconsideration had passed. Dr. Etzel points to no authority for the proposition that the Board’s jurisdiction is expanded where an agency acts too quickly in implementing an unreviewable pay reduction. We agree with the Board that this alleged violation does not create Board jurisdiction over the Pay Reduction Appeal.

For all these reasons, the Board did not err in concluding that it lacked jurisdiction to review Dr. Etzel’s Pay Reduction Appeal.

IV We have considered Dr. Etzel’s remaining arguments and find them unpersuasive. Thus, we affirm the Board.

AFFIRMED