I think it could be more than that. Studies have found that some people have burned off an increase of hundreds of calories a day just through an increase in fidgeting.
And then there's this (http://www.medicinenet.com/script/main/art.asp?articlekey=99...)
Despite the fact that all of the subjects spent the same amount of time in exactly the same confined space, the results showed large differences in the number of calories they burned. Some subjects burned as few as 1,300 calories in 24 hours, while others burned as much as 3,600 calories, a difference of 2,300 calories in one 24-hour period!
Keep in mind that most of what these subjects were doing would not be counted as "exercise".
