I've seen this claim considered many, many times over the years regarding Superman's build.
Muscles generally grow, especially to the extents required to get "built", by exercise... which causes muscles to become damaged, and the body to repair that damage by forming new muscle tissue to repair the damage. And damaging muscles to that extent and in the proper manner requires exertion that your current muscles can't completely handle without damage... and the ability for the muscle to be damaged.
Now, considering Superman... except maybe when he exerts himself to the max of his abilities (and arguably his muscles should remain mostly fine even then, and any damage healed too quickly to do nearly as much good as it might for a human), he really wouldn't be able to go through the tear, heal, repeat cycle. Because his muscles would not tear, or at least all but extreme loads. And, considering how heavy the Fortress key is and that Supergirl didn't even really have problems picking it up... basically, Superman couldn't and/or shouldn't be able to build muscles to any reasonable extent. Trying would require more weight than they'd be able to reasonably compact into a proper set of weights. And, due to the nature of his abilities/powers, it would be pretty pointless, even if possible, to do need exercise to that extent or otherwise find near impossible ways to manage it. Maybe he could get kryptonite to be able to work out and get muscle damage to be healed... but why would he?
When it comes down to it, Superman should always be a "lean average" build at most. He shouldn't be more muscular than humans, nor does he need to be. And, the idea of a non built Superman leads more credence to the description of Clark Kent. Not only should Superman not be built, the more built an actor is the less reasonable it becomes to see the person as a clumsy, kinda hopeless guy that's easy to ignore.
Someone ever tries to kill you... you try to kill em right back.
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