WITH SUB AS (
SELECT
   ORDER_NO                                                      AS OD_NO
  ,SLIP_COMMENT                                                  AS COMMENT
  ,length(SLIP_COMMENT)-length(replace(SLIP_COMMENT,',','')) + 1 AS CNT
FROM ORDERS
)
SELECT
    SUB.*
FROM SUB 
ORDER BY
    CNT DESC
   ,OD_NO DESC
;