fathom - 2:38 pm on Feb 5, 2013 (gmt 0)
I would say with a high degree of confidence that this isn't the case. The reason Google suggest reconsideration is because this tool is primarily targeting those who receive link warnings (and hence manual action, in many cases). Disavow has an impact whether you are manually penalised or not, although you cannot remove a manual penalty with disavow alone.
I wasn't refuting why you submit a reconsideration request I was stating you should not use the tool for PENGUIN there is no need to disavow what Google has already disavowed for you.