This is in the mini game where you have to shoo plastic cans into a large trashcan.
For the achievement you have to get 35 cans into the trashcan. I positioned myself halfway between the trashcan and the right edge of the screen and shot the cans that came from the right once. Some luck is involved here. It is easier if the trashcan is lower which seems to be random.
You can check out info on all the other achievements in this thread:
Some Guidance