To me, the leaves look like 'transitional' leaves, ie the leaves that milfoils have, that grow in-between emergent (aerial) and submerged leaves, and can be rather different from emergent and submerged leaves. In the off-growing season, and in plants stranded by receding water levels, these are sometimes the only leaves. Generally transitional leaves aren't used for diagnosis.
I think it is likely Myriophyllum variifolium partly because I suspect the leaves are transitional, but also because this site is relatively low - its not an alpine or subalpine location (although it is a cold valley) - and possibly more than 3 leaves per whorl. Flowering material would confirm either way; but that means waiting for summer or growing out some material. If it is M. alpinum then that would indeed be a good find, and a downward altitudinal extension relative to its other records.