There is a difference between FWH and Mash hopping. First wort hopping is when you add hops to the first runnings, and let them sit in there through the whole boil.
Mash hopping is where you add the hops to the mash, and they don't go into the boil. AFAIK, no one thinks mash hopping is good for anything better than wasting hops.
If I were to do FWH with an extract batch, I would add the hops to the wort after you pull the steeping grains. If you are adding the steeping water to a larger volume (full boil or so), wait until the whole boil volume gets up to 165-170 or so and then add hops.