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If you have a My Documents folder on that drive, it's definitely storing things there.
Since we don't know what else you might be forgetting to say, that's about all I could possibly suggest - just because you don't like it, doesn't mean a computer does what you want. Programs gotta program.
Same problem was reported back in 2017:
https://steamcommunity.com/discussions/forum/1/1473095331500203782/
It happens even when the HDD is empty. Once I close Steam, 5 minutes later it spins down. I've submitted a bug report, but I'll keep this thread alive in parallel so that others who encounter the same issue can find the information. In return, such people can help the visibility of the "bug" by posting in the bug report thread: https://steamcommunity.com/groups/SteamClientBeta/discussions/0/1627412171711829290/
given how greedy valve is, not unlikely
Seriously ... computers do this. SOMETHING got stored there, at some point, and it's tapping. This is a non-issue.
It has nothing to do with files, as I already explained it also happens when it's empty (formatted). Steam does a detection of all drives upon launch, and it is that action which spins them up.
I'll unsub from this thread now because replies like that are going to get annoying, and no fix will ever come from this thread.
But if you, the reader, are affected by the same problem, I do have a workaround for you. You can use this utility to spin down your drive(s) after starting Steam. Not sure how long Steam lets them stay spun down for and what actions within steam may cause them to spin back up, but it's working so far: https://www.majorgeeks.com/files/details/hddscan_for_windows.html
*can't understand why computer works when told to*
.... Seriously people, learn how your computers actually function.
I'd still like to see a solution. Other than upgrading all storage to SSD, anyway... I've got 3 TB of HDs laying around here not even needed yet.