WITH SplitComments AS (
    SELECT
        ORDER_NO,
        SLIP_COMMENT AS COMMENT,
        LENGTH(SLIP_COMMENT) - LENGTH(REPLACE(SLIP_COMMENT, ',', '')) + 1 AS CNT
    FROM
        ORDERS
)
SELECT
    ORDER_NO AS OD_NO,
    COMMENT,
    CNT
FROM
    SplitComments
ORDER BY
    CNT DESC,
    OD_NO DESC;