Personally if you are using a tool like Open Site Explorer and are already undertaking a link cleaning exercise. If you identify no follow links on spammy or dodgy sites then I would add to the disavow as you are doing this anyway.
I would rather clean all links as who know that Google will change next so I prefer to ensure everything is legitimate and as it should be even if our clients currently aren't being penalised.
I wouldn't go out of your way though to disavow these no follows if you are not cleaning your links anyway.