A former engineer has raised concerns the environmental watchdog's investigation into Stawell Gold's leaking tailings dam is not comprehensive enough.

The Environment Protection Authority (EPA) is currently assessing the extent to which toxic water, that includes cyanide, is leaking from the mine's 100 hectare dam.

The mine has reported increasing levels of cyanide are being detected in at least 11 bores, some of which are outside its mining licence.

Ian Magee sits on the environment review committee which oversees Bendigo's gold mines.

He said seeping groundwater was not the only issue.

"I don't think anybody is seriously looking also at the risk of a sudden discharge," he said.

"In other words, if there's a discharge to the surface and it goes into the local creek system and the Wimmera River, and I think that's just not seriously being talked about at the moment and probably should be considered in part of this process."

The acting north-west regional manager for the EPA, Danny Childs, said the agency had been working with the Department of Resources and the mine to ensure appropriate controls were in place for the tailings dam.

"Over a number of years there have been reports or assessments completed at the gold mine but in particular in recent times the EPA have issued a pollution abatement notice to the mine and that was mainly around a notification that impacts to the groundwater or detection of cyanide beyond the mining licence was identified," he said.

He said the agency had almost a month to review the mine's pollution audit.

"We'll assess the plan to ensure that it meets the requirements set out in the pollution abatement notice," he said.

"If it has, the recommendations from the plans submitted will be considered in further remedial notices.

"If a non-compliance of the pollution abatement notice is identified, EPA assesses all non-compliances against our compliance and enforcement policy."

The owner of Stawell Gold Mines, Canadian-based company Newmarket Gold, said remediation works on its leaking tailings dam would continue in accordance with the conditions of its licensing requirements.

In a statement, the company told the ABC it was working with the Victorian Government under an environmental audit, pollution abatement notice and other regulatory regulations.

The company said its environmental performance had been addressed over a number of years during forums reviewing Stawell Gold Mines.

It said groundwater delineation works, monitoring bore installation, pump back systems and bio remediation development were examples of the company's works to date.