Greenfield
Adventurer
I think the "non-lethal damage" may represent that fatigue.Read the Cold Water and Flowing Water sections of the rules compendium - that will make things more difficult.
Also, although I cannot find specific rules, fatigue should become a factor. Swimming, particularly in a hard current is very fatiguing. Once fatigued, continuing to swim (and you'd really have no choice) would cause exhaustion.
Now you'd be in deep crap.
Swimming a wide, cold, fast flowing mountain river isn't easy, although I would think you'd be unlikely to drown unless you got swept under when you were fatigued. More likely, you'd get busted against some rocks with injuries.
Alternately, one could rule that struggling against fast/cold water is like sprinting: One round per CON point, then you have a problem, whether you're holding your breath or not.