This paper reports the stability conditions for intense zonal flows (ZFs) and the growth rate γTI of the corresponding "tertiary" instability (TI) within the generalized Hasegawa-Mima plasma model. The analytic calculation extends and revises Kuo's analysis of the mathematically similar barotropic vorticity equation for incompressible neutral fluids on a rotating sphere [H.-L. Kuo, J. Meteor. 6, 105 (1949)]; then, the results are applied to the plasma case. An error in Kuo's original result is pointed out. An explicit analytic formula for γTI is derived and compared with numerical calculations. It is shown that, within the generalized Hasegawa-Mima model, a sinusoidal ZF is TI-unstable if and only if it satisfies the Rayleigh-Kuo criterion (known from geophysics) and that the ZF wave number exceeds the inverse ion sound radius. For non-sinusoidal ZFs, the results are qualitatively similar. As a corollary, there is no TI in the geometrical-optics limit, i.e., when the perturbation wavelength is small compared to the ZF scale. This also means that the traditional wave kinetic equation, which is derived under the geometrical-optics assumption, cannot adequately describe the ZF stability.