There are lots of ways to end up under 20W, under 10W at idle and then the board and drives are a larger % of power consumption.
Even picking processors that aren't particularly power miserly, with a decent board having the full compliment of over/underclocking settings including low vcore adjustment you can underclock most to surprisingly low power consumption, and a NAS doesn't need much at all in the way of CPU performance unless it were some kind of soft-RAID other than 0 or 1. CPU power is rated based on stock speed operation while you have the ability to go beneath that when underclocking, especially reducing voltage. Granted that's ignoring other power reduction features but for a NAS it's not so important to have those other power reduction features if you can just underclock and undervolt in the first place as there is not going to be a bottleneck for typical NAS functionality (but you haven't mentioned yet if you wanna run a DNS/mail/FTP/proxy/kitchen-sink like some people do).
I suggest you focus instead on the motherboard you want to use as there are variations in chipset power consumption, chipset performance (Via PCI bus = PITA), physical size and features per size, cost, manufacturer general quality and support. Just avoiding a separate video card can make more of a power difference, and choosing DDR2 based board makes memory cheaper (though for limited # of clients you don't need much memory).
Once you've settled on the board, get the complimentary CPU for it. There's not much need to spend a lot on a NAS, many people use the old P3 platforms merely because it not only does the job but is cheap if not free because they already have many if not all the parts already.