I have the exact same issue for my prelim choices. IMO a surgery prelim at a university program is likely better, but not surely. At least for me, nothing gets me more frustrated than doing dumb **** for my patients because the attending has decided he didn't need to learn anything new after he got out of residency. No amount of extra free hours can make up for that. Besides, at least in my experience talking to residents, university programs tend to have less scut work and more interesting things than community programs. And, IMO, the more scut work, the more likely things are disorganized => the less likely people are to care about ideal patient management. But, I know a community programs that is just as good or even better than some university programs, so it is much more important is how you felt about the culture of the place during your interview.