My p38 abs pumps seams to be running longer than it use to on start up, is this a sign the accumulator is failing?

 

It's very possible, the ABS Accumulator ( STC2784 ) goes bad with age.
When the accumulator can't hold the Nitrogen charge the ABS pump will cycle longer and more often to compensate.

When you replace the accumulator MAKE SURE to DEPRESSURIZE The System FIRST!!!!
And remember to use the NEW O ring.

Also check for ANY external brake fluid leaks in hoses, lines, calipers, etc. This can also cause the pump to run, but in this case (because you haven't mentioned a soft pedal) I'll bet it's the accumulator that has $hit the bed.