The $40\%$ of wall thickness criterion which has been used as a plugging rule is applicable only to a single cracked steam generator tubes. In the previous studies performed by authors, several failure prediction models were introduced to estimate the plastic collapse pressures of steam generator tubes containing collinear or parallel two adjacent axial through-wall cracks. The objective of this study is to examine the failure prediction models and propose optimum ones for non-aligned two axial through-wall cracks in steam generator tubes. In order to determine the optimum ones, a series of plastic collapse tests and finite element analyses were carried out for steam generator tubes with two machined non-aligned axial through-wall cracks. Thereby, either the plastic zone contact model or COD based model was selected as the optimum one according to axial distance between two clacks. Finally, the optimum failure prediction model was used to demonstrate the conservatism of flaw characterization rules for various multiple flaws according to ASME code.