WITH word AS(
    SELECT
        slip_comment,
        (LENGTH(slip_comment) - LENGTH(REPLACE(slip_comment, ',', '')))
        / LENGTH(',') +1 AS CNT 
    FROM orders
    )
SELECT
    order_no AS OD_NO,
    O.slip_comment AS COMMENT,
    cnt
FROM
    orders AS O
INNER JOIN
    word AS W
ON
    O.slip_comment = W.slip_comment
ORDER BY
    cnt DESC,
    OD_NO DESC