You'll need a letter of approval from the BATF on your design. Sucks, but it's just the way it works.
IF you are planning to buy a "kit" to build it up legal in semi-auto, get a COPY of the authorization letter from the BATF to keep on hand. Not a bad idea to call and check up if it's legit, too.
If it's an SBR (short barreled rifle) configuration you'll need to go through the process of getting THAT approved as well. Stock + barrel shorter than 16" is SBR. Overall weapon length, and other features, can also make it an SBR, or AOW.
I'm *really* surprised there are open-bolt guns allowed in semi-auto. The BATF has declared the vast majority of open bolt designs as "no-no" territory - there's page after page of them in the big federal book FFLs get. Reason is, anything holds down the sear (be it a toothpick or whatever), and the gun is instant-full-auto. Open bolt semi-auto designs are rediculously easy to convert to full auto (dropping the bolt serves as the trigger), or even select fire with a fun switch.
10 years is a long time, so be safe. If it's a one-off unapproved design, you might get lucky and just have it confiscated if caught, but you never know how far they'll push it once it hits the tech labs.
Those guys at the BATF tech branch have been known to cut & weld to get a gun declared "full auto".